Alejandra Montenegro Almonte
Member
Chair, International | Practice Co-Lead, Workplace Culture
Member and International Department Chair Alejandra Montenegro Almonte advises companies on high-stakes internal and government investigations and on complex compliance matters across a variety of business-critical areas including anti-corruption, workplace misconduct (including sexual harassment, discrimination, and retaliation), and other sensitive ethics and compliance topics.
Ms. Montenegro Almonte has helped a wide range of companies design and implement risk-based internal compliance programs and regularly advises on the design of safeguards to mitigate compliance risks arising from their unique business and operations. As a former General Counsel, she is adept at swiftly triaging and managing crisis situations to minimize client exposure while protecting her clients' interests vis-a-vis multiple stakeholders.
Ms. Montenegro Almonte recently served as an Independent Compliance Monitor for Wynn MA, LLC, focusing on workplace culture and conduct issues, including harassment and discrimination. She has also served in a leadership role in a monitorship team in an FCPA disposition. She is a native Spanish speaker and regularly conducts legal matters in both English and Spanish.
Before joining Miller & Chevalier, Ms. Montenegro Almonte was General Counsel for the North American and Latin American Division of gategroup, a global provider of products, services, and solutions related to the onboard experience of airline and rail passengers. In that role, she oversaw all legal affairs for gategroup's subsidiaries and provided strategic legal advice to the company's executive management teams in the United States, Canada, and Latin America on all legal, regulatory, and employment matters. While at gategroup, Ms. Montenegro Almonte developed and implemented compliance programs across her division. As Chair of gategroup's North American and Latin American Business Compliance Committees, she led a cross-functional management team to proactively manage compliance matters across the Americas.
Ms. Montenegro Almonte began her career as a litigation associate at two Am Law 100 firms. While at Harvard Law School, she served as president of the Harvard Legal Aid Bureau.
Representative Engagements
Workplace Culture and Conduct
- Represented a German manufacturing company into allegations of sexual assault by a senior executive in Asia of an employee in Latin America. In the context of cultural nuances and the severe nature of the allegations, the investigation navigated threats by third parties to reveal the allegations to the press and wider public, with a backdrop of significant power imbalances and complex questions about consent.
- Conducted an independent investigation on behalf of a large state university on governance, workplace conduct, retaliation, and culture issues affecting the highest level of the institution.
- Engaged by a special committee of the Board of Directors of a global non-profit professional membership organization to conduct a privileged and confidential external review into specific concerns raised by various stakeholders focused on the conduct of the organization's leadership.
- Represented an executive of a global humanitarian non-profit organization in connection with an investigation related to alleged racial discrimination, harassment, and retaliation.
- On behalf of a global extractives company, led a sensitive workplace misconduct investigation into allegations of harassment, bullying, and retaliation by members of a senior leadership.
- On a behalf of the Board of Trustees of large non-profit performing arts organization, led an internal investigation into allegations of harassment and racial discrimination by the organization Executive Director.
- For a global extractives company, conduct an internal investigation into allegations of gender discrimination and harassment arising from the Company's operations in Chile.
- Represented the Permanent Council of the Organization of American States (OAS) in an independent investigation into allegations against the Secretary General of the OAS.
FCPA and White Collar Investigations
- Represented a Latin America-based national oil company before the U.S. Securities and Exchange Commission and the U.S. Department of Justice in an investigation into allegations of $4B in cost overruns in connection with the construction of a refinery by one of its subsidiaries.
- Represented one of the world's largest multinational food producers in an internal review of certain cross-border transactions and food quality operations in Latin America.
- On behalf of global medical device company conducted two separate independent cross-border investigations based on internal whistleblower reports and allegations of corruption in local government tenders and potential misconduct by third parties.
- Led an independent FCPA investigation in India into questionable payments made to a third party engaging with local government agencies on behalf of an international medical device company.
- Represented senior executive and former public official in connection with DOJ investigation arising from crypto and related digital asset trading.
- Represented a multinational technology and manufacturing company before the U.S. Securities and Exchange Commission and the U.S. Department of Justice in an investigation of alleged FCPA violations arising from its Southeast Asian operations.
Compliance Counseling
- Led a global review of a Fortune 10 energy company's anti-corruption compliance program and related internal accounting controls against applicable statutory standards and best practices, in the context of ongoing investigations in multiple jurisdictions.
- Led a review of Fortune 100 information technology company's global anti-corruption program, with the goal of tailoring the compliance program to fit the company's needs following a corporate restructuring.
- For a multinational information technology company, conducted and advised on pre-acquisition due diligence of in connection with the acquisition of an information technology company in the Middle East.
- For an energy company, conducted post-acquisition due diligence of a newly acquired energy group with operations in Argentina, Brazil, Chile, Colombia, and Peru.
Other Regulatory Cross Border Matters
- Represented a multinational company in relation to alleged OFAC sanctions violations arising from its Latin American operations.
- Represented a European company with worldwide subsidiaries in a criminal proceeding under the International Traffic in Arms Regulations (ITAR). The matter was resolved in favor of client with no criminal charges.
International Arbitration
- Defended the Republic of Ecuador in an investor-state arbitration alleging a breach of the Canada - Ecuador Bilateral Investment Treaty. The Tribunal dismissed the case against Ecuador.
In-House Experience
- Division General Counsel, gategroup, 2011 - 2016
Rankings and Recognition
- Chambers Latin America: Corporate Crime & Investigations (International Counsel), 2024 - 2025
- Chambers Global: Corporate Crime & Investigations (Latin America-International Counsel), 2024
- Legal 500: Dispute Resolution: International Trade, 2021 - 2022
- Legal 500 Latin America: International Firms: Compliance and Investigations, 2021 - 2023
- The Best Lawyers in America®: Criminal Defense: White Collar, 2024
- Latinvex Latin America's Top 100 Female Lawyers: FCPA & Fraud, 2017 - 2022
- Global Investigations Review: Women in Investigations, 2021
- DC Bar Capital Pro Bono High Honor Roll, 2020
- DCA Live Emerging Women Leaders in Private Practice, 2019
Affiliations
- Board Member, Latino Student Fund, 2019 - present
- Committee Member, NCAA Division I, Infractions Appeals Committee, 2020 - present
- Leadership Council on Legal Diversity (LCLD) Fellow, 2017
- Board Member, DC Law Students in Court, 2015 - 2021
- Member, Global Legal Task Force Meeting, District of Columbia Bar, 2015 - 2018
- Board Member, Lagniappe Education Foundation, 2006 - 2018
- Co-Coordinator, HBA-DC Mentorship Program, Hispanic Bar Association, 2001 - 2002
Admissions
State Admissions
- District of Columbia
- New York
- Virginia
News and Events
Events
Speaking Engagement
ACI International Conference on the FCPA
Speaking Engagement
HBA-DC: An Evening with Member and International Chair Alejandra Montenegro Almonte
Speaking Engagement
Workplace Misconduct Compliance and Investigations: What Board Members and Senior Leaders Need to Know
Speaking Engagement
International Bar Association 2024 Annual Conference
Publications
External Publication
The Guide to Compliance – Third Edition: Introduction and U.S. Compliance Requirements Chapter
Internal Publication
2024 Latin America Corruption Survey
External Publication
The Guide to Compliance – Second Edition: Introduction and U.S. Compliance Requirements Chapter
External Publication
Harassment in the Restaurant Industry Part II: Employee Discipline
External Publication