Skip to main content

Dan Solomon's practice focuses on international corporate compliance, specifically the Foreign Corrupt Practices Act (FCPA), internal investigations, government enforcement actions, as well as economic sanctions and export controls. Dan advises companies on potential forced labor in their global supply chains, related supply chain mapping, supplier due diligence, and risk mitigation, with a particular focus on the manufacturing sector. Dan also represents companies and individuals in all phases of multilateral development bank (MDB) sanctions proceedings, including audits, investigations, settlements, Show Cause letter responses, post-sanction remediation efforts, and collateral issues.

Dan has extensive experience leading sensitive investigations across the globe, including those presenting complex legal, political, and reputational risks. Drawing on his in-house experience, Dan is particularly adept at right-sizing the scope of an investigation to get at the key issues without incurring unnecessary operational or financial burden, as well as effective communication with boards and company leadership on findings and remediation. 

On the compliance side of his practice, Dan focuses on the design and implementation of risk-based corporate compliance programs for large and small companies in a wide range of industries. Dan counsels companies seeking to build, improve, and defend their compliance programs. He advises clients on the development of key corporate compliance policies, procedures and controls, third-party risk management and compliance risk assessments, and due diligence regarding bribery and other compliance risks in a broad range of transactions. 

Dan previously served as General Counsel of SAIC General Motors, one of the largest and most successful automotive joint ventures in China. Prior to that, he was the Lead Counsel of Global Compliance and the Executive Director of Special Investigations and Anti-Corruption for General Motors Company. He was also seconded as an international trade and compliance lawyer at the Middle East operation of a publicly traded prime government contractor client during the Iraq and Afghanistan wars. 

Stemming from his many years of experience in-house in the U.S. and China, Dan brings a pragmatic, business-centric approach to legal advice and problem solving. He is well-versed in the nuances of the automotive and manufacturing sectors and has in-depth insight into the Chinese legal system and the regulatory and compliance risks encountered by multinationals doing business in China. 

Representative Engagements
  • Represented a multinational manufacturing company in several FCPA investigations and compliance matters, including allegations of potentially improper payments to government officials in the Commonwealth of Independent States, India, China, Thailand, Egypt, Kenya, Brazil, and Venezuela.
  • 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. 
  • Served as outside investigative counsel to the board of directors of a large privately held technology company to investigate potential cyber intrusion by Russian and Chinese subcontractors.
  • Current representation of several global automotive manufacturing companies in the U.S. and Asia on compliance with supply chain due diligence laws, including the Uyghur Forced Labor Prevention Act (UFLPA). 
  • 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.
  • Engaged by several U.S. and foreign publicly traded companies to conduct corporate-wide compliance program assessments and risk assessments.
  • 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. 
  • Appointed as Independent Integrity Adviser for an Asian-based technology company as a condition of their MDB settlement.
  • Represented a global engineering and construction company in global compliance review, including with respect to activities in Brazil, China, Egypt, Indonesia, Italy, Kuwait, Malaysia, Nigeria, Russia, Saudi Arabia, Thailand, United Arab Emirates, Venezuela, Vietnam, and Yemen.
  • Represented a multinational construction company in several investigations and compliance matters in the Middle East region, including allegations of embezzlement and fraud in connection with government contracts in support of Operation Iraqi Freedom and Operation Enduring Freedom. 
  • Conducted an internal investigation on behalf of a multinational agriculture company into allegations of improper payments to government officials in the Ukraine.  
  • Represented a publicly traded data center company in investigations involving alleged anti-competitive practices and improper payments to government officials in Southeast Asia.
  • Served as investigative counsel for a global pharmaceutical company to investigate alleged improper payments and procurement irregularities in connection with expansion of its manufacturing facilities in India. 
  • Conducted an internal investigation on behalf of a manufacturing company into allegations of kickbacks and other procurement irregularities in China.
  • Conducted an internal investigation on behalf of a publicly traded company into allegations of trade sanctions violations in China and Russia.
  • Engaged by publicly traded company to investigate potential embezzlement and corruption by third-party partner relating to an investment in China.
  • Engaged by a multinational automotive parts manufacturer to investigate potential workplace issues involving certain members of management in China.
  • Part of the monitorship team for a multinational company with a mandate to review and evaluate the company's global anti-corruption program on behalf of an MDB.
  • Engaged by the Audit Committee of a publicly traded company to investigate potential workplace issues involving certain members of senior management and the board of directors.
  • Represented a U.S. publicly traded company to investigate potential legacy labor law and collective bargaining compliance issues at their Brazilian subsidiary.
  • Represented a privately held aerospace and defense contractor to provide trade and anti-corruption compliance advice with respect to the sale, maintenance, and operation of refurbished Blackhawk helicopters for the Afghan Air Force.
  • Conducted a proactive compliance review of a client's soccer sponsorships and media rights in South America with the Fédération Internationale de Football Association (FIFA) corruption case as the backdrop.  
In-House Experience
  • General Counsel, SAIC General Motors Corporation Limited, Shanghai, China, 2017 - 2020
  • Lead Counsel, Global Compliance, General Motors Company, 2016 - 2017
  • Executive Director, Special Investigations & Anti-Corruption, General Motors Company, 2014 - 2016
Rankings and Recognition
  • Legal 500, GC Powerlist: China Teams, 2018 (for SAIC General Motors Corporation Limited)
Admissions
State Admissions
  • District of Columbia
  • Michigan
News and Events
Publications