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Paul Sumilas

Of Counsel

Paul Sumilas

Singapore

T:+65 6309 5442

Paul is a regulation and investigations lawyer based in Singapore. Paul focuses his practice on white collar criminal defense, compliance, and internal and government investigations for both corporations and individuals, with an emphasis on anti-corruption, including the US Foreign Corrupt Practices Act (FCPA), money laundering, sanctions, securities fraud, and insider trading. Before moving to the Singapore office in 2016, Paul spent five years in Norton Rose Fulbright’s Washington, DC office.

Paul has extensive experience advising clients in relation to compliance and internal and government investigations, including FCPA and general anti-corruption compliance. His experience includes conducting internal and government investigations, representing clients before government agencies, designing and implementing compliance programs, advising clients with respect to third party and M&A due diligence, conducting compliance training for employees and third parties, and managing risk assessments. He has worked for multinational clients across a variety of industries (energy, oil and gas, construction, aerospace, life sciences, telecommunications, financial services, retail, maritime) and around the world. In Asia, he has advised clients on issues in Singapore, China, Hong Kong, Japan, South Korea, Indonesia, Malaysia, Thailand, Cambodia, and Papua New Guinea. He also has extensive experience working with clients in India, Europe, Latin America, Africa, and Australia.

Paul works closely with clients to develop strategies to manage and mitigate compliance risk and has assisted corporate and individual clients appearing before the US Department of Justice, the US Securities and Exchange Commission, the US Federal Reserve, the US Food and Drug Administration, the UK Serious Fraud Office, the UK Financial Conduct Authority, and the Hong Kong Independent Commission Against Corruption.

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  • Education

     

    • 2007 - J.D., William & Mary School of Law
    • 2007 - M.B.A. College of William & Mary
    • 2001 - B.A., Psychology, Georgetown University
    • Paul was admitted to practice law in Virginia in 2007 and in Washington D.C. and before the Eastern District of Virginia in 2008.

     

  • Representative experience
    • Represented a private Latin American construction and engineering firm before the US Department of Justice with respect to corruption and money laundering allegations
    • Represented executives of Japanese company involved in multiple investigations before the US Department of Justice and the US Food and Drug Administration
    • Managed internal investigation for oil and gas services company resulting from allegations of FCPA violations that required extensive documents collection across Asia (Singapore, Indonesia, Thailand, China) and in the United States, over 50 witness interviews, multiple DOJ meetings, and advising the client on enhancing its compliance program
    • Represented senior executives of a multinational financial services firm as part of a large-scale FCPA investigation by the US Department and Justice, US Securities and Exchange Commission, and US Federal Reserve following allegations of improper hiring practices in Asia
    • Advised a US-based financial services firm about corruption and disclosure issues resulting from potential misconduct in Cambodia.
    • Represented a Venezuelan national allegedly involved in corrupt activity
    • Advised a Malaysia-based company on US sanctions-related issues resulting from recent M&A activity
    • Advised US-based company under investigation by Indian government authorities for alleged bribe payments
    • Conducted an internal investigation for a US-based maritime company involving allegations of bribes in exchange for beneficial tax treatment in China and South Korea
    • Managed a complex anti-corruption internal investigation for a large, multinational company involving Latin America and Europe, including developing an investigation strategy, interviewing high level executive, and presenting findings to the company's board of directors and senior executives
    • Provided an Australia-based investment entity advice on potential legal liability resulting from investment activity
    • Assisted a US company with an internal investigation into allegations of corruption and kickback schemes at its Chinese subsidiary
    • Advised a UK multinational company with respect to a proposed acquisition of a South African company following allegations of corrupt activity at the target
    • Advised a German-based company about potential compliance risks associated with expansion in the United States
    • Advised a Japan-based financial institution with respect to managing compliance risk in light of the "Lava Jato" investigation in Brazil involving allegations of bribery, money laundering and anti-competitive behavior across various industries
    • Conducted a risk-based assessment of a Fortune 50 company's international operations for potential anti-corruption issues and conducted on-site reviews in Asia, including over 30 interviews
    • Designed corporate compliance programs for clients, including drafting manuals, policies, and procedures, conducting training and advising clients on an ongoing basis
    • Conducted risk assessment for US public company's Mexican operations following allegations of FCPA and Mexican anti-corruption law violations
    • Advised client in relation to third-party subpoena requesting documents and information related to an FCPA investigation conducted by the SEC
    • Represented a US telecommunications company in a variety of false advertising cases, including Lanham Act claims in federal court and complaints in front of the National Advertising Division
    • Defended an individual cooperating with a wide-ranging and high-profile federal public corruption investigation
    • Defended an individual accused of violating the Federal Elections Campaign Act in both the district and circuit courts
    • Represented a pro bono client in a criminal matter involving identity theft and potential immigration status issues
  • Admissions
    • Attorney at Law, admitted in Virginia
    • Attorney at Law, admitted in Washington DC
  • Rankings and recognitions
    • Washington DC Rising Star, criminal defense: white collar, Thomson Reuters, 2014 - 2017
  • Publications
    • Co Author, “OFAC amends Burma (Myanmar) sanctions: More changes may come”, Norton Rose Fulbright - Legal update, May 2016
    • Co Author, “DOJ launches pilot program for FCPA cases”, Norton Rose Fulbright - Legal update, April 11, 2016
    • Co Author, “Turbulent FCPA trial concludes with unexpected plea deal - Probation and criminal fines for former PetroTiger CEO”, Norton Rose Fulbright - Legal update, June 24, 2015
    • Co Author, “Largest FCPA criminal fine: Alstom settles FCPA charges for US$772M”, Norton Rose Fulbright - Legal update, January 8, 2015
    • Co Author, “Avon and subsidiary agree to pay US$135M in penalties for alleged bribery”, Norton Rose Fulbright - Legal update, January 2015
    • Co Author, “FCPA caution to individuals: Two more former employees of Direct Access Partners plead guilty to FCPA and Travel Act violations”, Norton Rose Fulbright - Legal update, December 2014
    • Co Author, “Recent FCPA enforcement actions highlight areas of concern for companies”, Norton Rose Fulbright - Legal update, December 17, 2014
    • Co Author, “Cutting the ties that bind - Company obtains favorable FCPA Opinion for government official buyout”, Norton Rose Fulbright - Legal update, March 27, 2014
    • Co Author, “A global bulletin on recent business ethics and anti-corruption developments”, Business ethics and anti-corruption world, February 2014
    • Co Author, “FCPA settlement for German-based engineering company”, Norton Rose Fulbright - Legal update, December 20, 2013
    • Co Author, “Hiring a problem: Avoiding the pitfalls of employing relatives of government officials”, Legal update, September 18, 2013
    • Co Author, “Anti-Corruption Regulation in 2013 and a Review of 2012 Major Developments”, The International Law Firm of Fulbright & Jaworski - Securities, March 4, 2013
    • Co Author, “2011 Anti-Corruption Year In Review”, Law 360, March 19, 2012
    • Co Author, “Prosecuting Individuals To Deter FCPA Violations”, Law360, November 30, 2011
    • Co Author, “Making the Call: Voluntary Disclosure in an Uncertain Environment”, ABA National Institute on Securities Fraud, November 2011
    • Co Author, “The Latest In FCPA Enforcement”, Law360, November 1, 2011
    • Co Author, “To Pay Or Not To Pay For Gov't Official Travel”, Law360, September 26, 2011
    • Co Author, “China Remains An FCPA Hotspot”, Law360, February 24, 2011
    • Co Author, “SEC Initiates Investigation of Financial Institutions and Sovereign Wealth Funds for Potential FCPA Violations”, Fulbright Briefing, February 18, 2011