Emily Lewis is a solicitor at Fulcrum Chambers specialising in investigations and corporate compliance, particularly in relation to the UK Bribery Act.

Emily has been involved in some of the most complex and high-profile corporate investigations and prosecutions brought by the SFO.

Her experience includes reviewing, analysing, and advising on the re-design and implementation of corporate compliance programmes; advising upon and executing adequate procedures to prevent bribery within the meaning of the UK Bribery Act; advising upon appropriate responses to internal whistle-blower reports; conducting internal investigations; and advising on the applicability of legal professional privilege at different stages of internal investigations.

Emily has in-house experience gained during a secondment to the legal and compliance department of a multinational extractives client in 2019.

Emily joined Fulcrum as a paralegal in 2013.

Experience

White Collar Defence & Advisory

Emily advises and acts for multi-national clients across a wide range of white-collar crime and regulatory matters, and has acted as defence counsel for clients under investigation by the SFO and DoJ.

Recent highlights include:

  • Advising ENRC in relation to the SFO’s long-running investigation of alleged bribery and corruption in Africa.
  • Advising Alstom in relation to the SFO’s investigation and prosecution of bribery and corruption offences, including in relation to the company’s appeal and sentencing hearings.
  • Representation of and advice to a multi-national client in relation to the DoJ’s on-going investigation into Huawei and breaches of sanctions on Iran.
  • Providing in-house assistance to a compliance team at multinational oil and gas company under a DoJ monitorship.
Bribery & Corruption

Emily advises and acts for multinational clients on issues relating to bribery and corruption, including in relation to the Bribery Act.

Significant experience includes:

  • Advising a multinational transport company and a multinational mining company upon adequate procedures to prevent bribery within the meaning of the UK Bribery Act, and providing assistance with the execution of such procedures.
  • Advising ENRC in relation to the SFO’s long-running investigation of alleged bribery and corruption in Africa.
  • Advising a multinational oil & gas company in relation to allegations of bribery received through whistleblowing hotline.
Due Diligence

Emily advises clients on third party risk, including in relation to transactions and CSR initiatives in high risk jurisdictions, and assists clients in the review and optimisation of their compliance processes and procedures in order mitigate operational compliance risks.

Significant experience includes:

  • Providing in-house assistance to a multinational oil and gas company in respect of new counterparty application and the distribution of the CSR budget to projects in high risk jurisdictions.
  • Reviewing the CPDD policy and procedures of a large mining company and advising upon the redesign and implementation of a best practice model.
  • Reviewing high risk counterparty files for large multinational companies and providing bespoke, expert advice on risk mitigation strategies in the context of complex contractual relationships.
Investigations

Emily has significant experience of conducting internal and regulatory investigations across a wide range of sectors.

Significant experience includes:

  • Representing ENRC in relation to the SFO’s long-running investigation of the company for alleged bribery and corruption in Africa.
  • In-house experience at a multinational oil and gas company where she managed and conducted internal investigations into allegations of corruption received through the whistleblowing hotline and advised company management on the investigatory process.
  • Conducting several investigations into high risk transactions for a multinational mining company, in order to advise upon whether the company’s compliance processes and procedures were utilised appropriately, such that the company could be considered to have adequate procedures in place to prevent bribery within the context of the UK Bribery Act.
  • An internal investigation into allegations of corruption for a multinational transport company, and advising on the application of legal professional privilege in the context of investigations.
  • Representation of and advice to a multi-national client in relation to the DoJ’s on-going investigation into Huawei and breaches of sanctions on Iran.
Regulatory Investigations

Emily has represented and defended multinational corporate clients in relation to investigations undertaken by the SFO.

Significant experience includes:

  • Advising ENRC in relation to the SFO’s long-running investigation of alleged bribery and corruption in Africa.
  • Advising Alstom in relation to the SFO’s investigation and prosecution of bribery and corruption offences, including in relation to the company’s appeal and sentencing hearings.
  • Representation of and advice to a multi-national client in relation to the DoJ’s on-going investigation into Huawei and breaches of sanctions on Iran.
  • Providing in-house assistance to a compliance team at a multinational oil and gas company under a DoJ monitorship.
Compliance & ESG

Emily advises multinational clients on the design and implementation of corporate governance and compliance programmes, including providing workshops and training to compliance teams, senior professionals, and business leaders.

Significant experience includes:

  • Advising clients on the adequacy of their compliance procedures following the introduction of the Bribery Act 2010.
  • Advising a multinational mining company in respect of its ongoing compliance processes, practices and policies, as well as the redesign of its Group-wide compliance function.
  • Conducting interactive compliance training and workshops for multinational clients.
Dispute Resolution

Emily has represented corporate clients in high-value international commercial arbitrations and was responsible for managing teams of lawyers and paralegals as part of two long-running concurrent Oil & Gas arbitrations (ICC and UNCITRAL rules) against a State entity.

Sector Experience

Mining

Emily has represented and acted for a number of large, global mining companies on a wide variety of matters ranging from SFO investigations into bribery and corruption, internal investigations, and providing advice on compliance issues and best practice. She has particular experience of working with clients in the mining sector in Africa.

Significant experience in the sector includes:

  • Advising ENRC in relation to the SFO’s long-running investigation into alleged bribery and corruption in Africa.
  • Advising a multinational mining company in respect of its ongoing compliance processes, practices and policies, as well as the redesign of its Group-wide compliance function.
  • Reviewing high risk counterparty files for a multinational mining company and providing bespoke, expert advice on risk mitigation strategies in the context of complex contractual relationships.
Oil & Gas

Emily has provided advice and support to the legal and compliance team at a multinational oil and gas company under DoJ monitorship as a secondee to the legal and compliance department. Emily has also advised upon the conduct of commercial arbitrations in the oil and gas sector.

Significant experience in the sector includes:

  • Advising a multinational oil and gas company in respect of new counterparty application and the distribution of the CSR budget to projects in high risk jurisdictions.
  • Reviewing and revising compliance policies and procedures for oil and gas company.
  • Managing and conducting internal investigations into allegations of corruption received through the whistleblowing hotline at a multinational oil and gas company; advising company management on the investigatory process.
  • Managing teams of lawyers and paralegals as part of two long-running concurrent Oil & Gas arbitrations (ICC and UNCITRAL rules) against a State entity.
Extractives

Emily has significant experience in the extractives sector, having represented mining and oil & gas companies in relation to SFO investigations. Emily also regularly advises extractives clients on compliance issues and best practice.

Significant experience in the sector includes:

  • Advising ENRC in relation to the SFO’s long-running investigation into alleged bribery and corruption in Africa.
  • Secondment to legal and compliance team of a multinational oil and gas company under DoJ monitorship.
  • Advising multinational mining company in respect of its ongoing compliance processes, practices and policies, as well as the redesign of its Group-wide compliance function.
  • Reviewing high risk counterparty files for a multinational mining company and providing bespoke, expert advice on risk mitigation strategies in the context of complex contractual relationships.
Logistics & Supply Chain

Emily has investigated and advised upon third party risk in relation to the supply chain of a fast-growing logistics start-up.

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