Lillian Howard Potter

Special Counsel

Potter, Lillian Howard

Lillian Howard Potter's practice focuses on government and internal corporate investigations. She has particular experience in matters involving the Foreign Corrupt Practices Act (FCPA) and related laws.

Ms. Potter has extensive experience representing multinational corporations and individuals in complex government and internal investigations. She regularly represents clients in FCPA enforcement matters before the US Department of Justice and the Securities and Exchange Commission, as well as investigations by other US government agencies and other investigative bodies and commissions. Ms. Potter also represents clients in anti-corruption investigations by the World Bank, international organizations such as the United Nations, and foreign law enforcement authorities. She has represented clients in government and internal FCPA investigations across the globe, including in Europe, Asia, the Middle East, Africa and Latin America.

Ms. Potter also counsels clients in numerous industries on a variety of challenging FCPA issues, including advising on issues in mergers and acquisitions, joint ventures and other cross-border business arrangements. She routinely leads internal global anti-corruption compliance risk assessments for multinational corporations and advises on the strength of their anti-corruption compliance programs and internal governance structures. Ms. Potter works with clients across geographies and industries to develop and implement effective global anti-corruption compliance programs and policies. She has provided anti-corruption training programs around the world, in both English and Spanish.

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 immigrant crime victims in federal criminal proceedings, the United Farm Workers in their administrative challenge to federal farmworker regulations, domestic abuse victims in immigration proceedings, and the family of an Iraq war veteran in congressional testimony. Prior to joining the firm, Ms. Potter was a Skadden Fellow at Southern Migrant Legal Services, where she represented migrant farmworkers in federal employment litigation.

Publications & News


January 12, 2018

Global Anti-Bribery Year-in-Review: 2017 Developments and Predictions for 2018

This past year, which marked the 40th anniversary of the U.S. Foreign Corrupt Practices Act (“FCPA"), demonstrated that the FCPA continues to be a powerful tool in combating corruption abroad and encouraging compliance at global companies.

December 22, 2017

Global Magnitsky Sanctions Target Human Rights Abusers and Government Corruption Around the World

This article also appeared on the New York University School of Law Compliance and Enforcement Blog.

November 29, 2017

DOJ Announces New FCPA Corporate Enforcement Policy

Today, “[d]ue to the unique issues presented in FCPA matters,” Deputy Attorney General Rod Rosenstein announced a new FCPA corporate enforcement policy published in a revision to the United States Attorneys' Manual.

February 7, 2017

Global Anti-Bribery Year-in-Review: 2016 Developments and Predictions for 2017

The past year was consequential for FCPA enforcement in numerous respects, including blockbuster penalties, new policy initiatives, and the SEC's first DPA with an individual for FCPA violations.

April 8, 2016

DOJ Launches FCPA Pilot Program to Encourage Corporate Voluntary Disclosure and Cooperation

On April 5, 2016, the Fraud Section of the Department of Justice's Criminal Division issued an enforcement plan and guidance laying out three steps it is taking to intensify Foreign Corrupt Practices Act enforcement.

April 1, 2016

Busy 1st Quarter For FCPA Enforcement

An article by Jay Holtmeier, Kimberly Parker, Erin Sloane, Lillian Potter, Jeanne Gellman and Erin Kuhls, published in the March 31, 2016 issue of Law360, explores cases indicating that even as the DOJ has renewed its focus on individuals, it continues to pursue large cases with corporations—and that the SEC continues to broadly define a "thing of value" under the FCPA.

March 23, 2016

Busy Q1 Yields Several Significant FCPA Resolutions

Recent actions announced by the DOJ and SEC during the first quarter of 2016 suggest that this year may be a significant one for FCPA enforcement.

February 2, 2016

Global Anti-Bribery Year-in-Review: 2015 Developments and Predictions for 2016

Among other significant developments, 2015 saw the U.S. Department of Justice (the “DOJ” or the “Department”) document a policy priority of holding individuals accountable for corporate wrongdoing. This policy was laid out in the “Yates Memorandum”—announced by Deputy Assistant Attorney General Sally Quillian Yates—and related changes the DOJ made to the U.S. Attorney’s Manual.

December 16, 2015

Brockmeyer and Stokes Offer Four Benefits of Cooperation and Four Ways Companies Can Go Wrong in Their Internal Investigations

An article featuring commentary from Lillian Howard Potter, published by The FCPA Report, Vol. 4, No. 26 (December 16, 2015).

December 2, 2015

Top FCPA Enforcers Discuss Evolving and Diverging Enforcement Approaches and the Defense Bar Responds

An article featuring commentary from Lillian Howard Potter, published by The FCPA Report, Vol. 4, No. 25 (December 2, 2015).

Recent Highlights

  • Representation of companies and individuals in numerous FCPA enforcement matters before the Department of Justice and the Securities and Exchange Commission
  • Representation of companies in anti-corruption investigations by the World Bank
  • Representation of a large foreign technology conglomerate in ongoing SEC and DOJ investigations into alleged FCPA violations at a US-based 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 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 


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JD, magna cum laude, Georgetown University Law Center, 2000, Articles Editor, Georgetown Law Journal

BA, cum laude, Hollins College, 1997

Bar Admissions

District of Columbia





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

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