James C.Dunlop (Jim)

Of Counsel

Chicago + 1.312.269.4069 São Paulo + 55.11.3018.3939

Jim Dunlop has 25 years of experience in cross-border investigations, FCPA anticorruption, and transactional due diligence practice in Latin America. Fluent in Portuguese, Jim has represented some of the world's largest companies when they or their employees face indictment in the United States or abroad, or when they are alerted to potential criminality within their organization or in connection with an acquisition.

Practicing from Chicago and throughout Latin America, Jim has secured dismissal of all criminal charges brought in Brazil against an oil company and 11 of its executives; he also represented a mining company and its executives against Brazilian charges of environmental crimes and homicide. In addition, Jim has led the internal investigation of an international retailer in Brazil as part of a complex FCPA investigation conducted by the DOJ and SEC in four countries and numerous internal investigations and anticorruption due diligence in the automotive, energy, financial services, food and beverage, green energy, health care, personal care, pharmaceutical, retail, and software industries.

Jim has extensive experience coordinating local counsel in criminal matters arising under foreign law. He also has defended companies, individuals, and nonprofits against charges of accounting fraud, bank fraud, money laundering, price-fixing, health care fraud, and public corruption.


  • Fortune 500 medical company conducts internal investigation in South America involving allegations of distributor FCPA violationsJones Day represented a Fortune 500 medical company in internal investigations in Brazil and Argentina involving potential violations of U.S. antibribery laws, including the FCPA.
  • Fortune 500 company conducts internal anticorruption investigationJones Day advised a Fortune 500 company on an internal anticorruption investigation involving alleged payments made to political figures through unions associations.
  • Fortune 500 medical device company conducts mock dawn raidJones Day devised and conducted a mock dawn raid and training at the Brazilian headquarters of a U.S.-based Fortune 500 medical device company.
  • Energy company undergoes FCPA internal investigation in EuropeJones Day conducted an internal investigation for an energy company involving allegations of FCPA and U.K. Bribery Act violations in Europe.
  • U.S. industrial manufacturer seeks compliance training for joint venture in BrazilJones Day advised a U.S. industrial manufacturer with compliance training involving a joint-venture and subsidiary operations in Brazil under U.S. antibribery laws, including the CAP, and under the Brazilian Clean Companies Act.
  • Chevron defends against allegations of environmental damage from oil seeps off coast of BrazilJones Day is serving as lead U.S. counsel for Chevron with respect to various legal and administrative proceedings arising out of oil seeps that occurred off the coast of Brazil in November 2011 and March 2012.
  • SunPower acquires TenesolJones Day advised SunPower Corporation in its acquisition of Tenesol SA, a global solar provider headquartered in La Tour de Salvagny, France.
  • Executive of international shipping company defends antitrust criminal investigationJones Day represented an executive of an international shipping company that was subject to an investigation by the Department of Justice, Antitrust Division.
  • Major university conducts investigation into statistical data disseminated by law schoolOn behalf of a large public university, Jones Day conducted an investigation into the accuracy of grade point averages, LSAT scores, acceptance rates, career placement data, and other information that the university's law school had reported to the American Bar Association, U.S. News & World Report, and other third parties.
  • African businessman defends criminal ITAR caseJones Day represented a prominent African businessman arrested in Switzerland on an international arrest warrant concerning the export of dual use military equipment to an African nation and in connection with his extradition to the United States.
  • Former officer of Nicor settles SEC enforcement actionJones Day represented the former officer of Nicor Inc. in connection with an SEC enforcement action resulting in a favorable settlement on a non-intentional fraud basis with no "penalty" assessment.
  • Former VP Sales of Drummond resolves sales kickback caseJones Day represented a former VP of Sales for Drummond, Inc., an industrial cleaning products company, who was a target of an honest services kickback investigation.
  • General counsel of affiliate of U.S. heavy equipment manufacturer avoids criminal EAR and OFAC chargesJones Day advised the general counsel of a foreign affiliate of a U.S. heavy equipment manufacturer who was a target of a criminal export controls prosecution involving the shipment of heavy equipment to a proscribed country.
  • Ready-mix company avoids criminal price-fixing chargesJones Day advised a regional ready-mix company in a criminal price fixing investigation.
  • Trust bank conducts special committee investigationJones Day provided counsel to a special committee of a trust bank and conducted a year-long investigation on its behalf relating to executive compensation practices in response to shareholder demands.
  • Wall Street investment bank cooperates in public corruption investigationJones Day represented a Wall Street investment bank in a public corruption investigation led by the Department of Justice (DOJ) and involving parallel prosecutions and risk of parallel civil proceedings lasting several years and reaching across business units.
  • Pharmaceutical and device manufacturers conduct compliance risk assessmentJones Day conducted a compliance risk assessment of two manufacturers' existing compliance programs.
  • CFO and director of Career Education Corporation obtains dismissal of shareholder derivative and securities fraud class actionsJones Day represented former Career Education Corporation Director and Chief Financial Officer Patrick Pesch in actions brought by shareholders of Career Education Corporation, a provider of for-profit post secondary education that operates more than eighty campuses, against the company and its board of directors in shareholder derivative and securities fraud class action litigation alleging fraud and breach of fiduciary duty in connection with certain of the company's accounting marketing practices.
  • Former controller of Bally Total Fitness obtains dismissal of shareholder derivative actionJones Day advised the former controller of Bally Total Fitness, which operates fitness centers nationwide, in connection with shareholder derivative and securities fraud class action litigation filed by shareholders against the company, its board of directors and certain current and former officers, alleging fraud and breach of fiduciary duty in connection with certain of the company's accounting practices.
  • Speaking Engagements

    • December 10-11, 2014
      Brazilian Companies and the U.S. Foreign Corrupt Practices Act: Exploring the Reach of the FCPA
    • February 2013
      The Foreign Corrupt Practices Act: Overview, Enforcement Trends and Impact on Mergers & Acquisitions
    • February 9, 2012
      Brazilian Companies and the U.S. Foreign Corrupt Practices Act: Exploring the Reach of the FCPA
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