Sam Eastwood

Sam is one of a limited number of practitioners outside the US with experience of acting as an independent monitor: he has acted as Independent Compliance Monitor for Macmillan Publishers Limited, reporting to the World Bank and the Serious Fraud Office. He has also acted as an independent compliance consultant in relation to the compliance program of a Chinese company, reporting to the African Development Bank and has acted on a number of other quasi monitor mandates linked to World Bank sanctioned entities helping the companies to apply for release from debarment.

Sam was part of the UK project team that developed the International Standards Institute (ISO) standard for anti-corruption management programmes and previously sat on the British Standards Institute’s panel for the drafting of the Anti-Bribery Standard and conducted subsequent pilot reviews of this Standard.

Sam is recognised as a Band 1 practitioner in Chambers UK Financial Crime: Corporate and a leading individual in Legal 500 UK - Corporate Crime (including fraud, bribery and corruption).

Sam is a qualified Solicitor Advocate and accredited mediator.

• Sam has also had quasi-Monitor appointments for an Australian international engineering consultancy and an Azeri technology company which had also been debarred by the World Bank. The companies were both encouraged by the World Bank’s Integrity Compliance Officer to retain an independent adviser to help them review and reinforce their compliance programme so that they could apply for release from debarment at the earliest possible stage - which they both successfully did.

Investigations

• Carrying out internal investigations for a multinational mining equipment manufacturer, which resulted from a whistleblower report while a global compliance review was taking place. This involved extensive data review, forensic analysis and key personnel interviews as well as the management of remediation arising from the termination of third party engagements.
• Advising Telia Sonera, a Scandinavian multinational, in a substantial investigation and review of its Eurasian acquisitions (Azerbaijan, Kazakhstan,Tajikistan, Nepal, Georgia) reporting to the Chairman of the Board who set out our findings at Telia Sonera’s Annual General Meeting.
• Investigation into alleged corrupt dealings with Chinese state-owned entities by US and European entities of a multinational corporate. Reporting to the board of directors and design of remediation programme and compliance improvements.
• Representing Tullow plc in relation to its joint venture operations in Ghana (with Kosmos and Anadarko) and a World Bank investigation into the activities of their joint venture’s FPSO operator.
• Investigation into two Chinese Distributors of a multinational manufacturing company in response to a whistleblower report.
• Advising a large management consultancy practice on its response to allegations relating to its involvement with Gupta associated entities in South Africa and conducting an investigation into its activities in that jurisdiction for two State owned entities.
• Investigation in Kazakhstan for a global logistics company relating to its customs activities following press reports in the Wall Street Journal.
• Investigation in Turkey for a technology company in response to a whistleblower allegation relation to the procurement of an important licence in that jurisdiction.
• Investigation into the Indian operations of a FTSE 100 manufacturing company and advising them on the appropriate compliance steps to respond to weaknesses identified in their compliance program.
• Investigation into the activities of a former African country manager of an oil and gas multinational and related compliance programme review.
• Numerous other internal investigations for a range of industries (financial institutions, engineering, technology, oil and gas, etc).

Compliance

• Designing and implementing a global compliance programme for a large multinational company, which involved a secondee working in the in-house legal team, fieldwork in Brazil, China, India, Kazakhstan, Russia, Ukraine, the United States and Finland, numerous investigations and managing potential criminal exposure in Austria, Poland and other jurisdictions.
• Audit and testing of a global manufacturer's compliance programme, including transaction review and interviews in China, Singapore, Dubai, Europe and the United States. Reporting data-driven results and recommendations to the board of directors. Developing and executing remediation plans relating to financial control and compliance process improvements, training and employee discipline.
• Assisting a leading aerospace and defence company to establish a consistent methodology to assess the remuneration paid to third parties that meets the required standards of international anti-bribery legislation.
• Assisting an oil and gas multinational with the management of its high risk third party program mandated by the US Authorities.
• Reviewing the compliance programme of a multinational construction company and delivering to the Board recommendations for its development.
• 15 month review of financial institution’s third party management programme which included secondments of associates to facilitate the management of the project.
• Designing and delivering anti-corruption programs or elements of programs (training, risk assessments, third party programs, investigation and internal audit functions) for a range of corporates across numerous sectors.
• Advising a Big 4 Audit practice on its response to indications of impropriety relating to the activities of one of its audit clients African subsidiaries.
• Advising multinational companies on the development of human rights related policies and procedures, responses to the demands of institutional investors regarding their human rights and labour welfare policies and procedures and responses to human rights related legislation including the Modern Slavery Act.
• Advising financial institutions on their response to the Criminal Finances Act (failure to prevent tax evasion) and helping them to work up a risk assessment and suitable policies and procedures to address the identified risk.

Business and Human Rights

• Advising multinational companies across a range of sectors on
• engagements related to the UK Modern Slavery Act including advising on exposure, mitigation and Modern Slavery Act statements
• the development of human rights policies and procedures, human rights due diligence
• reviewing and reinforcing complaints mechanisms and speak up programs
• addressing the demands of institutional investors and related reporting requirements.
• Investigating a whistleblower’s complaints in connection with labour conditions in the Asian factory network of an international retailer
• Investigating child labour and other human rights related allegations arising in connection with a European multinational’s African based supplier’s operations
• Carrying out an human rights impact assessment in connection with the fall out of a fishing industry corruption scandal
• Conducting human rights due diligence in relation to the acquisition of an international sportswear manufacturer.
• Advising an international defense company on its human rights exposure and developing their human rights risk mitigation strategy.
• Advising on the response to complaints made to the UK’s National Contact Point
• Delivery of human rights training to Kenyan businesses together with the Danish Human Rights Institute as part of a UK Government-sponsored initiative.

Transaction support

• Conducting mergers and acquisitions integrity due diligence for various international companies, as well as developing post-acquisition compliance integration plans.

• Band 2: Financial Crime. Sam Eastwood advises financial institutions and corporations on compliance and regulatory matters, including anti-bribery and corruption issues. "Sam Eastwood has provided excellent support." Chambers UK
• Listed in the 'Hall of Fame' and as a key lawyer for Regulatory Investigations and Corporate Crime and a key lawyer for EU and Competition Legal 500
• Sam Eastwood advises financial institutions and corporations on compliance and regulatory matters, including anti-bribery and corruption issues. "He is very knowledgeable, hands-on and easy to work with, and provides excellent advice." "His expertise and insights are invaluable." Chambers UK 2022, Financial Crime
• Listed in the Hall of Fame and as a key lawyer for Regulatory Investigations and Corporate Crime, Sam 'is a guru in the field' and is 'friendly, to the point and great to work with'. Legal 500
• Listed in the 'Hall of Fame' and as a 'Leading individual' and under 'Other key lawyers' for Regulatory Investigations and Corporate Crime Legal 500
• Sam Eastwood  advises financial institutions and corporations on compliance and regulatory matters, including anti-bribery and corruption issues. Chambers UK
• Listed as a 'Leading Individual' for Financial Crimes Chambers UK
• Listed under 'Other key lawyers' for Commercial Litigation and Fraud Legal 500