Robert M. Appleton attorney profile image

Robert M. Appleton

rappleton@mmlawus.com
1185 Avenue of the Americas, 21st Floor
New York, NY 10036
T: (212) 880-3997
F: (212) 880-3998

Robert Appleton is a globally recognized anti-corruption and Foreign Corrupt Practices Act expert and one of the foremost FCPA and AML practitioners in the world. A former U.S. Department of Justice and United Nations prosecutor, he has led, supervised or managed more than 1000 corruption and compliance cases in over 150 countries in his more than 25-year career. 

Mr. Appleton has served in leading enforcement, chief compliance and legal roles in a number of international organizations, including the United Nations where he served for three years as Chief of the first ever UN Anti-Corruption Unit. He most recently led Government Investigations and White Collar practice groups at two large law firms. Prior to that, he served as Director of Financial Investigations and Forensic Audit Deputy Inspector General at the Global Fund to Fight AIDs, Tuberculosis and Malaria from 2009-2014. 

He focuses his practice on assisting global, foreign and US companies, organizations and individuals in regulatory and enforcement actions in FCPA, AML, fraud and corruption, insider trading and related matters.  Through his many roles throughout his career, Robert has developed broad and extensive contacts throughout the world, in government, international and national organizations, and enforcement authorities in Africa, Asia, the Middle East, Latin America and Europe – and North America.

Mr. Appleton is also an asset recovery expert, representing numerous entities and organizations with US regulatory issues as well as domesticating foreign judgments. He has most recently focused his efforts on Brazil based financial institutions and asset management organizations and assists them in the recovery of funds in the US and abroad.  Robert is a Member of Offshore Alert. He has been involved, and also called upon as an authority, regarding many of the world’s most prominent corruption scandals.  Most recently, Mr. Appleton has been active in addressing the Lavo Jato scandal in Brazil, assisting companies navigate the FCPA risks and defending individuals. He has been featured in many Latin American publications on the prosecutions and its aftermath, including Conjure, Brazil’s leading law publication. In February 2018, Robert planned, organized and moderated the first public discussion of the Lavo Jato investigations in Sao Paulo, which featured the leading authorities from the FBI and Brazil’s MPF and public prosecution service.  

He has also conducted significant internal investigations for companies and large international NGOs, and served as a Monitor for companies debarred by international organizations. Mr. Appleton has helped numerous entities and organizations successfully navigate enforcement actions.  Robert was recently retained by one of the largest international NGOs to conduct a parallel internal investigation with USAID’s Inspector General of the Syrian relief program activities in Turkey.  He  has also been retained by a number of international organizations and NGOs as well as national authorities in Africa and Asia, to assist in training managers, investigators and compliance professionals in global anti corruption risks; performing due diligence in mergers and acquisitions; and of vendors, suppliers and third party agents.
   
Mr. Appleton was appointed in 2006 by the UN Secretary General to serve as Chairman and Chief of Unit for the United Nations Procurement Task Force, the UN’s first ever organization-wide anti-corruption, anti-bribery, and anti-fraud task force that was charged with addressing allegations of financial impropriety in the global UN system.

While serving as Chief Investigation’s Counsel for the United Nations Independent Inquiry Committee, Mr. Appleton served as lead counsel of the Procurement Forensics Team responsible for investigating all bribe payments to the Iraqi regime and provided advice to the Committee chairs on recovering assets and losses in foreign jurisdictions.

Mr. Appleton spent 15 years with the Department of Justice in the District of Connecticut, first as an Assistant U.S. Attorney in the Criminal Division before being promoted to Branch Chief, Supervisory Assistant U.S. Attorney.

Practice Areas

In the News

Education

  • J.D., Magna Cum Laude, Western New England School of Law, 1989
  • B.A., Cum Laude, Emory University

Admissions

  • Connecticut
  • New York (Inactive)
  • U.S. Court of Appeals, Second Circuit
  • U.S. District Court, District of Connecticut
  • U.S. District Court, Eastern District of New York
  • U.S. District Court, Southern District of New York
  • U.S. Supreme Court