Ruti Smithline

Ruti Smithline is co-chair of the firm’s Investigations + White Collar Criminal Defense group and co-chair of the firm’s Latin America Desk. Her practice focuses on complex litigation, with an emphasis on white collar criminal defense, SEC enforcement, securities litigation, and corporate internal investigations.

Ruti is a member of the firm’s global FCPA + Anti-Corruption Task Force. She regularly advises clients on cross-border investigations, global compliance programs and anti-corruption due diligence for acquisitions, joint ventures, and private equity transactions. Ruti has represented individual and corporate defendants in cross-border criminal investigations, SEC enforcement matters, and other regulatory proceedings, including matters related to trade sanctions and anti-money laundering. She has experience conducting corporate internal investigations both domestically and internationally, often advising clients on remedial measures responsive to the issues investigated.

Ruti was born and raised in Colombia and is fluent in Spanish. She has conducted investigations, seminars and anti-corruption training in Spanish throughout Central and South America.

Ruti has been recognized by industry leading publications including Chambers & Partners, where she is ranked in the USA guide for Litigation: White Collar Crime & Government Investigations in New York and nationally for their FCPA category, in addition to being ranked in the Latin America guide for Corporate Crime & Investigations across the LatAm region. She has also been recommended by Legal 500 US in their Corporate Investigations and White Collar Criminal Defense category, was recently selected by LatinVex as one of "Latin America's Top 100 Lawyers: FCPA & Fraud" for 2021, and has also been named to Global Investigations Review's "Women in Investigations" 2018 survey, which recognizes the top 100 leading female investigations specialists from around the world.

Ruti received her J.D. from The George Washington University School of Law, where she graduated with honors and as a member of the Order of the Coif. She received her B.A. degree cum laude from Cornell University. She is admitted to practice law in New York and New Jersey.

FCPA Representative Matters

• Monitorship Team for a Large South American Company. Working as key team member for the independent compliance monitor as appointed by the DOJ and two separate multilateral development banks for a large South American company in the wake of a multi-jurisdictional resolution worth billions of USD.
• Fortune 500 Company. Conducted an internal investigation into potential FCPA violations at a foreign subsidiary of a Fortune 500 multinational corporation. Conducted more than 60 interviews of employees, reviewed business lines and relationships with key customers and distribution channels, and conducted forensic analysis of accounting records and internal controls. Investigation included a review of business units in more than 15 countries to assess FCPA risks.
• A Multinational Agricultural Company. Conduct an internal investigation into allegations of improper payments made to a government official in a Latin American country, which included assisting with recommendations to enhance and improve the Company’s compliance program and implementation of those remedial measures.
• A Multinational Electronics Company. Representation in an SEC FCPA investigation involving conduct in Latin America related to our client’s engaging in a business relationship with a company that was subsequently involved in a government corruption scandal.
• Audit Committee of International Company. Represented the audit committee of an international supplier of agricultural products in its internal investigation resulting from a whistleblower complaint alleging violations of the FCPA in the Middle East. This matter was one of the first cases to be reported to the SEC under its whistleblower rules enacted in 2011. After we completed the investigation and reported the result to the SEC, it declined to conduct an investigation of its own and closed the file.
• Fortune 500 Company. Represented a Fortune 500 company with anti-corruption due diligence in connection with the acquisition of a foreign telecom company with substantial operations in Africa, Latin America, Southeast Asia and the Middle East.
• Global Retailer. Represented a senior executive of a global retailer in connection with an investigation by the DOJ, SEC and other agencies into possible violations of the FCPA in Mexico, Brazil and other countries.

Other Representative Matters

• A Foreign Bank. Representation in connection with inquiries from banking regulators regarding the Bank’s relationships with customers and entities involved in well-known corruption and money laundering schemes as well as the Bank’s own BSA/AML controls, which implicates bank secrecy laws and the privacy and data security laws of various jurisdictions.
• A U.S. Holding Company for a Multinational Bank. Conducted an independent assessment of the Company’s compliance program, including reviewing the bank’s governance, internal controls, audit, and filtering systems, to ensure compliance with U.S. sanctions laws pursuant to a Consent Order entered into with the Board of Governors of the Federal Reserve System.
• A State-Owned Bank. Conducted a multi-year internal investigation into anti-money laundering controls and potential violations of U.S. sanctions laws at the New York branch of the Bank, which culminated in a deferred prosecution agreement to settle allegations made by federal and state regulators. The representation also involved securing a motion to dismiss in a related civil action where Plaintiffs sought over US $1 billion directly from the Bank related to allegations of fraudulent conveyance.
• Multi-Faceted Investigation of University Grants. Advised a major U.S. research University in a criminal and civil investigation of alleged false claims relating to federal research grants and contracts.
• Various Individuals in South America. Representation of individuals in South America working for U.S. headquartered Bank in investigation by DOJ regarding potential violations of Bank Secrecy Act and anti-money laundering laws.
• Former Mortgage Executive. Represented the Chief Financial Officer of one of the largest national mortgage originators, now bankrupt, in an SEC investigation and related shareholder litigation arising from the credit crisis.