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Rebekah J. Poston


Rebekah Poston, after serving as an Assistant US Attorney with the US Attorney's Office in Miami, Florida and as a Special Attorney with the Department of Justice's Organized Crime and Racketeering Section in Cleveland, Ohio, now focuses her practice on defending complex domestic and international white collar criminal cases. She has successfully represented multinational, public and private corporations, brokerage firms and banks, airlines and shipping lines, maritime brokers, medical device and pharmaceutical companies and industrial manufacturing and agricultural companies, as well as their officers, directors and employees. Rebekah has counseled and defended on matters involving a wide range of issues including the Foreign Corrupt Practices Act (FCPA), the USA PATRIOT Act, money laundering, environmental crime, Internet fraud and identity theft, tax evasion, bank, securities and tax fraud, customs and embargo violations, asset seizures, forfeitures and healthcare fraud and abuse. She has written FCPA corporate compliance programs and conducted FCPA trainings, audits and internal investigations for Fortune 100 and 500 companies around the globe.

Rebekah heads the firm’s global FCPA/anticorruption and compliance team consisting of more than 50 partners and associates located in the US, Latin America, Asia Pacific, Europe and the Middle East. She also leads the firm’s Criminal Justice Act federal trial team for the Southern District of Florida. She is an active participant in the firm’s Women’s Initiative Group and Lateral Hire Committee.

In 2010, Rebekah was inducted as a Fellow into the American Bar Foundation. An authority on white collar criminal defense, she was named to Who’s Who Legal 100 (2014) as one of the world’s top lawyers in the area of Business Crime Defense. She is consistently named as one of Florida’s Super Lawyers in her field, a ranking that places her among the top 5 percent of all Florida’s lawyers. She also has been listed each year in The Best Lawyers in America since 2003, named as one of Florida’s Legal Elite by Florida Trend magazine each year since 2004, and is regularly listed in South Florida Legal Guide as one of South Florida’s leading lawyers in her field of white collar criminal defense. In 2010, she was selected by South Florida’s Legal Guide as one of eight women lawyers who had excelled in their legal careers.

Rebekah has presented at several national conferences on such topics as FCPA M&A due diligence, implementing FCPA compliance plans in Latin America, and how to conduct an FCPA internal investigation. She has also trained the legal, business and compliance departments throughout Latin America of a major Fortune 100 company on FCPA. She presented on the “Implications of Criminal Law in an International Arena” and on the “Key Issues in Managing International Business Controversies” at The Florida Bar’s International Law Section’s International Litigation and Arbitration Conference. She has also been a panel member for the University of Miami School of Law’s Center for Ethics and Public Policy. She also has spoken to the Latin American/Caribbean Conference, The Association of International Bank Auditors and the Miami Free Trade Zone as well as the Association of Internal Certified Public Accountants and Florida Atlantic University. Rebekah also gives lectures to banks, auditors, and public and private industries on such topics as antimoney-laundering compliance and cyber crime; the FCPA; the Federal Sentencing Guidelines; and preserving the attorney/client privilege and attorney work product doctrine in domestic and international corporate investigations and voluntary disclosure to government agencies. She presented at the Criminal Justice Ethics Symposium for the ABA Criminal Justice Section, Florida, White Collar Crime Committee on “Avoiding Ethical Land Mines: Recognizing the Limits of Advocacy” and regularly presents on “Legal Ethics for the Criminal Practitioner” for Lorman Seminars.

Rebekah also has an extensive 30-year background in immigration and nationality law, particularly in representing individual and multinational clients. She represents the interests of both individuals and US businesses that employ non-US nationals. Rebekah assists multinational corporations with the preparation and filing of various petitions with the US Citizenship and Immigration Services (USCIS), which include such visa categories as EB-5s, Es, H-1Bs, Ls, Os, Ps, Rs and TNs. She and her immigration team assist with the preparation of exchange visitor (J-1) visas for non-US nationals who are coming to the US to participate in programs authorized by the Department of State. She and her team also have extensive experience with PERM labor certifications, immigrant visas, and citizenship and naturalization matters. Rebekah has special experience in the areas of non-immigrant and immigrant visas for high net worth individuals, multinational executives and specialized knowledge workers throughout Latin America and Europe.

Representative Experience – White Collar
  • Representing Fortune 500 companies in conducting their FCPA due diligence in global mergers and acquisitions and joint ventures.
  • Training various Fortune 500 companies’ employees, compliance, auditing and legal staff on FCPA, UK Bribery Act and anticorruption laws and compliance.
  • Conducting FCPA risk assessments for foreign subsidiaries of US publicly controlled and traded companies.
  • Writing FCPA and UK Bribery Act compliance codes for US public companies.
  • Training US public companies’ domestic and foreign legal departments on the FCPA and UK Bribery Act.
  • Serving on the FCPA monitorship team in the Weatherford International case.
  • Orchestrating and conducting FCPA and anticorruption training in the native language for a US public company in multiple countries.
  • Representing Fortune 500 companies in FCPA internal investigations in Brazil, the Dominican Republic, Greece, Honduras and Italy including revising and drafting corporate FCPA compliance and integrity codes.
  • Writing FCPA compliance and integrity codes for a commercial aviation joint venture in China.
  • Representing US brokerage firms in federal grand jury investigations for alleged broker misconduct and investor fraud.
  • Representing a major US commercial airline on charges of illegal transportation of hazardous material.
  • Representing a public logistics company in a federal grand jury investigation of alleged handling and processing of hazardous waste without proper permits.
  • Representing a major land developer’s sales agent on charges of Clean Water Act violations and mail and wire fraud.
  • Representing a cruise line’s chief engineer in a federal grand jury investigation for alleged Clean Water Act violations regarding oil pollution on the high seas.
  • Representing cargo airlines in federal seizures of aircraft and raids by federal law enforcement agencies.
  • Representing cargo airlines in Customs and Department of Homeland Security regulatory inspections and investigations.
  • Representing importers in federal seizures of their goods by US Customs and Border Protection.
  • Representing individuals on charges of Internet fraud.
  • Representing individuals and companies on charges of Internet gaming.
  • Representing a company preparing its IPO in an internal investigation regarding early recognition of revenue issues.
  • Representing individuals charged with US and international tax fraud.
  • Representing individuals charged with securities fraud.
  • Representing victims of international securities fraud.
  • Representing individuals in the United States whose extradition was sought from their native countries of Israel, Hong Kong, Sweden and the Czech Republic.
  • Representing Czech Republic nationals in a Mutual Legal Assistance Treaty request.
  • Handling prisoner transfers of US citizens to the United States under Prisoner Transfer Treaties.
  • Representing public and private companies in internal investigations regarding such issues as Office of Foreign Assets Control (OFAC) compliance, premature revenue recognition, federal contract fraud, money laundering, immigration and I-9 compliance, and employee embezzlement and theft.
  • Advising public and private companies on training their employees and management on how to respond to search warrants executed by state and federal law enforcement and regulatory agencies.
  • Representing non-US persons whose US visas have been revoked or canceled.
  • Representing individuals seeking to have their intelligence records corrected or deleted from state and federal law enforcement databases.

Outside Presentations – White Collar
  • “Brazil’s New Clean Company Act,” KPMG’s Annual Shareholders Forum, U.S. Automobile Manufacturers, Detroit, Michigan, January 2014.
  • “Anti-Corruption enforcement Is Alive, Well and Costly,” Global Technology Distribution Council (GTDC), February 2014.
  • “Key Issues in Managing International Business Controversies” panel presentation, Florida Bar Twelfth Annual International Litigation and Arbitration Conference, February 2014.
  • “Managing Your Reputation and Anti-Bribery Risks Under the UK Bribery Act, Foreign Corrupt Practices Act and Australian Criminal Code,” Squire Sanders (US) LLP Australian Anti-Bribery and Corruption Three Part Seminar Series, May 2014.
  • “Economic Crime in the Digital Age: Latest Developments in Anti-Corruption, Fraud and Cyber Crime” panel discussion, PwC Conference, June 2014.
  • “Designing A Robust Program for Successful M&A Transactions: Due Diligence, Contract Negotiations and Post-Acquisition Integration,” Consero Corporate Counsel Forum.
  • “Foreign Corrupt Practices Act in Mexico – Implementing FCPA Compliance Programs and Mitigating Risk,” Stafford Publications, Inc.
  • “Criminal Law in the International Arena,” Florida Bar International Litigation and Arbitration Committee.
  • “FCPA Third Party Due Diligence in Latin America,” American Conference Institute, FCPA Boot Camp.
  • ABA International Section, Criminal Division, Teleconference: DOJ and SEC Update on the FCPA.
  • “FCPA and Anti-Corruption,” British-American Chamber of Commerce.
  • “Foreign Corrupt Practices Act in the Middle East, Compliance Strategies Given the Region's Unique Cultural and Governmental Intricacies,” Strafford Webinar.
  • “Foreign Corrupt Practices Due Diligence in an M&A and JV Setting,” Georgia State Bar.
  • “Planning and Managing International Transactions, Business Operations and Risks,” Corporate Counsel Institute Seminar, Ohio State Bar.

Representative Experience – Immigration
  • Representing EB-5 immigrant visa investors.
  • Representing employers and individuals with non-immigrant and immigrant visa petitions filed with the US Citizenship and Immigration Services (L, E, P, R, O, H-1B, J).
  • Representing an energy company in an I-9 government audit.
  • Representing a large agricultural business in an I-9 government audit.
  • Representing an international flight school in a J-1/M-1 government audit.
  • Representing a public company that owns post-secondary education institutions throughout the United States in a SEVIS/SEVP audit and investigation.
  • Representing individuals whose criminal history records need to be cleared to pave the way toward lawful permanent residency and naturalization.
  • Representing non-US nationals in government filings to correct inaccurate information housed in official government databases to facilitate their entry into the United States.

  • Interview: "Employees of non-US Government Instrumentalities – Are They Foreign Officials Under the FCPA?" Ethic Intelligence.
  • “The Long Arm of the Law: Why Non-US Companies Need to Comply With the Foreign Corrupt Practices Act,” originally published on www.complinet.com.
  • “Extraction and Compliance: New Reporting Requirements for Issuers Involving Oil, Natural Gas or Minerals,” originally published on www.complinet.com.
  • “The Dodd-Frank Act Together With Factors Unique to China Combine to Create the Perfect Storm,” originally published on www.complinet.com.
  • “Papa’s Got a Brand New Bag: Is DOJ Criminal Division Changing Its Tune on Voluntary Disclosure Alert?” available at www.squiresanders.com.
  • “FCPA Due Diligence in Acquisitions,” The Review of Securities & Commodities Regulations.
  • “FCPA Military and Law Enforcement Alert,” available at www.squiresanders.com.
  • “FCPA Telecommunications Alert,” available at www.squiresanders.com.
  • “Money, Money – Who’s Got the Money,” Daily Business Review.
  • “Assisting International Companies in Their Fight Against Corruption,” Counsel to Counsel Magazine.
  • “Diligence Can Close Biggest Loophole for Money Laundering: Real Estate,” Daily Business Review.
  • “Investigating Fraud in Emerging Developing Markets,” A.S. Pratt and Sons and Sheshunoff Information Services and Journal of Payment Systems Law.
  • “502 Protection and Selective Waiver,” ABA Litigation Reporter.
  • “New Global Trends in FCPA Enforcement,” Counsel to Counsel Magazine.
  • “Avoiding Foreign Entanglements,” Daily Business Review.
  • “McNulty Reverses Course on Corporate Rights, But Don’t Expect Smooth Sailing,” Andrews Corporate Officers and Directors Liability Litigation Reporter.
  • “Two Bows in the B Visa Quiver: B Visas Based on Medical Treatment and the Jones Act Claim,” Immigration Daily and ILW.com.
  • “SEC Ramps Up End-of-Year Sanctions,” South Florida’s The Business Journal and MSNBC.com.
  • “Telling Tales for Leniency: Like Other Columbia Executives Might Try Bargaining,” Modern Healthcare.
  • “How Far Up Will It Go? ‘First Phase’ of Columbia Probe Nets Three Indictments,” Modern Healthcare.
  • “Responding to Search and Seizure Threats,” Provider.
  • “Solid Action Plan Can Counter Search Warrant Shock,” American Medical News.
  • “Treat Threat of Search and Seizure Like Threat of Fire,” Health Care Strategic Management.
  • “Preparing for a Search Warrant: Review Affidavit, Film Search,” Healthcare Business & Legal Strategies.
  • “Immigration Policy Stagnated,” South Florida Business Journal.

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T +1 305 577 7022


University of Miami, J.D., 1974
University of Miami, B.S., magna cum laude, 1970


U.S. Ct. of App., Eleventh Circuit
U.S. Dist. Ct., Middle Dist. of Florida
U.S. Dist. Ct., S. Dist. of Florida

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