Tetyana V. Gaponenko



Tetyana Gaponenko's practice focuses on internal investigations, government enforcement actions and compliance counseling. She has particular experience in matters involving the US Foreign Corrupt Practices Act (FCPA) and related laws. Her clients include major multinational corporations, technology companies and financial institutions. 

Ms. Gaponenko represents clients in both civil and criminal investigations before the US Department of Justice (DOJ) and Securities and Exchange Commission (SEC). As part of her investigations practice, she manages complex case teams, conducts witness interviews, supervises multijurisdictional document collections and reviews, and prepares external and internal presentations and reports. She also liaises with legal, compliance and audit teams on remedial steps. 

In her compliance counseling practice, Ms. Gaponenko helps clients assess potential risk and design effective compliance programs. She drafts and revises policies and procedures to ensure compliance with applicable laws, and works with clients to implement them. Ms. Gaponenko regularly conducts anti-corruption compliance trainings in both English and Russian. She also has experience advising clients on FCPA-related issues in cross-border mergers and acquisitions and joint ventures. 

Ms. Gaponenko joined the firm's New York office in 2010 and moved to the Palo Alto office in 2015. She is a member of the New York and California bar associations. 

Recent Highlights

  • Representation of the audit committee of a global networking and communications company in a DOJ and SEC investigation of FCPA issues in Russia, Thailand and other countries, resulting in declinations from both agencies.
  • Representation of a major multinational industrial conglomerate in a DOJ and SEC investigation into government sales in the Middle East, resulting in non-public declinations from both agencies.
  • Representation of a financial institution in the SEC's first enforcement action involving the hiring of foreign officials.
  • Representation of a global financial services firm executive in an SEC investigation into alleged securities fraud.
  • Conducting internal investigations for public and privately held clients, including a multinational technology company, a medical technology company, a software systems vendor, an industrial manufacturer, and an oil services company, into corruption and other issues in Eastern Europe, South America, and Asia.
  • Conducting a global due diligence review of third parties in North and South America in connection with a criminal investigation of a large defense contractor and manufacturer by the DOJ and the UK Serious Fraud Office.
  • Advising a major multinational industrial conglomerate in connection with a DOJ FCPA investigation related to a potential acquisition target, as well as pre-acquisition anti-corruption due diligence of acquiree's operations in South America and Central Asia.

Pro Bono

  • Successfully represented an asylum-seeker from The Gambia in removal proceedings in Immigration Court in New York, as well as subsequent family reunification and permanent residency petitions with the US Citizenship and Immigration Service.
  • Represented a New York inmate in civil rights action alleging violations of 42 U.S.C. § 1983.

Past Experience

Prior to joining WilmerHale, Ms. Gaponenko served as a law clerk at the East Bay Community Law Center in Berkeley, California, where she represented Spanish-speaking clients in affirmative immigration proceedings. She also won asylum for clients from Mali, Kenya and Guatemala while volunteering with a clinic in law school.

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.

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.

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.

January 27, 2015

Global Anti-Bribery Year-in-Review: 2014 Developments and Predictions for 2015

The year 2014 witnessed several notable developments in the enforcement of the Foreign Corrupt Practices Act. In Global Anti-Bribery Year-in-Review: 2014 Developments and Predictions for 2015, WilmerHale attorneys discuss notable trends and developments in 2014, and look ahead to possible trends in 2015.


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JD, University of California, Berkeley School of Law, 2010, Publishing Editor, California Law Review; Senior Editor, Berkeley Journal of International Law

BSFS, International Politics, magna cum laude, Georgetown University, 2007

Bar Admissions


New York




Spanish (Conversational)

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