Lillian Howard Potter

Special Counsel

Lillian Howard Potter's practice focuses on advising companies of all shapes and sizes in every corner of the globe on compliance with the Foreign Corrupt Practices Act (FCPA) and related anti-corruption laws. She has particular expertise in helping companies view their FCPA compliance efforts critically, through the lens used by prosecutors and regulators, and in strengthening their programs and controls accordingly. She works frequently with companies during government or internal investigations, or as companies prepare for the appointment of an independent compliance monitor by the US government.

Ms. Potter provides creative advice to a range of clients, whether multinational corporations in highly regulated industries seeking to enhance their already sophisticated FCPA compliance programs to meet the evolving expectations of prosecutors or start-up companies to whom FCPA compliance is new, working together closely to create a bespoke compliance program that addresses the company’s corruption risks. Ms. Potter provides strategic advice to clients grappling with complex anti-corruption compliance issues across the spectrum. She collaborates with companies to design all aspects of FCPA compliance programs—including third party due diligence and related controls—and helps clients with related rollout and messaging; conducts risk assessments large and small; works with internal and external audit resources to audit, monitor and strengthen key controls; provides compliance training to employees, officers and directors at all organizational levels; leads FCPA due diligence for high-risk mergers and acquisitions and advises on subsequent compliance integration; advises on measures for mitigating corruption risk for joint ventures, consortia and cross-border transactions; and develops actionable solutions to urgent FCPA compliance issues in real time. 

Ms. Potter’s compliance advice is informed by her long experience with and active representation of multinational corporations in complex government and internal investigations around the world. She regularly represents clients in FCPA enforcement matters before the US Department of Justice and the Securities and Exchange Commission, as well as in corruption-related investigations by other US government agencies, foreign law enforcement authorities and international bodies, such as the United Nations, the World Bank and other multilateral development banks. 

Additionally, Ms. Potter is the senior editor of the leading treatise in the field, Complying with the Foreign Corrupt Practices Act (Matthew Bender, 10th ed. 2021).

Pro Bono Practice

Ms. Potter maintains an active pro bono practice. She currently serves as a guardian ad litem for children in the Washington DC foster care system. Previously, she has represented domestic abuse victims in immigration proceedings, immigrant crime victims in federal criminal proceedings, the United Farm Workers in their administrative challenge to federal farmworker regulations and the family of an Iraq war veteran in congressional testimony. Prior to joining the firm, Ms. Potter was a Skadden Fellow at Texas RioGrande Legal Aid, where she represented migrant farmworkers in federal employment litigation.


    • Participation in WilmerHale’s work as the DOJ/SEC–appointed independent FCPA compliance monitor for a German-based supplier of global dialysis products and services in connection with the company’s $231 million resolution of FCPA charges
    • Advising a technology company on enhancements to its anti-corruption compliance program and related controls prior to the appointment of a DOJ-appointed independent FCPA compliance monitor for the company
    • Advising companies under investigation by the DOJ and SEC on how to remediate key compliance gaps and strengthen their FCPA compliance programs, and on how to frame those changes with prosecutors and regulators
    • Advising numerous global companies in multiple industries on design, creation and rollout of all aspects of their FCPA compliance programs, including development of policies and procedures, third party management systems, and internal controls
    • Conducting corruption risk assessments and providing companies with practical advice and hands-on assistance in strengthening their anti-corruption compliance programs and controls
    • Representation of a large foreign technology conglomerate in SEC and DOJ investigations into alleged FCPA violations at a US-based avionics subsidiary
    • Representation of a major media and communications company in connection with the successful resolution of the US government's investigation into its Argentine joint venture's role in the FIFA soccer corruption scandal
    • Representation of companies in anti-corruption investigations by the World Bank and other multilateral development banks
    • Representation of a major financial institution in the SEC's first enforcement action involving the hiring of relatives of foreign officials
    • Representation of a large US multinational corporation in due diligence investigations of an acquisition target, ultimately resulting in non-public declinations from both the DOJ and SEC
    • Representation of Armor Holdings, now a subsidiary of BAE Systems, Inc., in its July 2011 FCPA settlement with the DOJ and SEC relating to the actions of a former employee of the company who later went on to become the informant in the DOJ's 22-defendant FCPA sting case
    • Participated in the representation of Boeing in an internal corporate investigation concerning the US Air Force KC-767 Tanker Program, and in related federal inquiries by the Defense Department and the Justice Department 

Insights & News


  • Education

    • JD, Georgetown University Law Center, 2000

      magna cum laude Articles Editor, Georgetown Law Journal
    • BA, Hollins College, 1997

      cum laude Phi Beta Kappa
  • Admissions

    • District of Columbia

    • Maryland

  • Clerkships

    • The Hon. Stephanie K. Seymour, US Court of Appeals for the Tenth Circuit