Biography
Courtney Hague Andrews is a partner in the Firm's Global White Collar Practice. She focuses her practice on white collar and compliance matters.
Courtney's white collar experience includes conducting internal investigations and representing and advising multinational companies in civil and criminal matters, including in the context of enforcement actions undertaken by the US Department of Justice, the US Securities and Exchange Commission, and other US and foreign enforcement authorities. She has substantial experience in matters involving the US Foreign Corrupt Practices Act ("FCPA"), including conducting investigations and complying with post-settlement disclosure and reporting obligations.
She also has experience in providing strategic advice regarding third-party relationships, proactive transaction monitoring, creating and assessing compliance and training programs, conducting risk assessments and compliance audits, and conducting and evaluating anti-corruption due diligence in the context of mergers and acquisitions.
Prior to joining White & Case, Courtney was a Fellow at the International Human Rights Clinic at The George Washington University Law School. She then worked for a stint as a foreign associate with a major firm in Ecuador.
Courtney spent more than six years in the Firm's Washington, DC, office before transferring to Los Angeles.
Experience
Representative work includes:
Representation of Microsoft Corporation and Microsoft Hungary in connection with FCPA investigations by the US Department of Justice and the US Securities and Exchange Commission related to operations at Microsoft Hungary resolved by negotiated resolutions with each authority.
Conducting internal investigations regarding transactions in various countries in Central and Eastern Europe, Russia, Kazakhstan and China, some of which were under active review by the US Department of Justice and/or the US Securities and Exchange Commission, as well as by one or more non-US enforcement authorities.
Representation of a multinational company in connection with investigations into potential trade sanctions violations by its Russian subsidiary.
Representation of a multinational company in connection with an investigation by the European Anti-Fraud Office.
Representation of a multinational company in connection with a review by the French Anti-corruption Agency.
Representation of a multinational company in connection with its reporting obligations to US authorities.
Representation of a multinational hardware distributor in connection with potential FCPA violations involving a subsidiary in Latin America.
Representation of a bank in connection with investigations into possible violations of federal and state antitrust and fraud laws as well as of the Commodity Exchange Act.
Representation of a multinational company in connection with potential FCPA violations in Russia and Germany.
Advising the Board of Directors of a private equity fund in an internal investigation involving possible FCPA violations by the Latin American subsidiary of a US portfolio company.
Recalibrating Your Disclosure Decision: How Recent DOJ Guidance, Enhanced Incentives, and Enforcement Trends are Changing the Self-Reporting Equation, ACI FCPA and Anti-Corruption Annual Conference, December 2025
The Shifting Dynamics of Resource Nationalism – Legal Strategies for Cross-Border Investors, 71st Annual Natural Resources and Energy Law Institute, July 2025
Special Institute on International Mining and Energy Law, Development, and Investment, April 2025
Recalibrating Your Disclosure Decision: How Recent DOJ Guidance, Enhanced Incentives, and Enforcement Trends are Changing the Self-Reporting Equation, ACI FCPA and Anti-Corruption Annual Conference, December 2024
FCPA Enforcement and Compliance, ACI FCPA and Anti-Corruption Annual Conference, December 2023
"Las Acciones de Clase en Materia de Derechos Humanos en los Estados Unidos," at Acciones de Grupo y Clase en Casos de Vulneraciones a los Derechos Humanos, sponsored by the Defensoría del Pueblo de Colombia and the Grupo de Investigación en Derechos Humanos de la Universidad del Rosario, Bogotá, Colombia, 2010
9th Circuit backs SEC's no-denials settlement rule – but leaves the door open to future challenges | White & Case LLP (co-author with Darryl Lew, Tami Stark, Jason Ho and Paula Kates).
Ten Takeaways from the DOJ Criminal Division's New Playbook on White Collar Enforcement Priorities | White & Case LLP (co-author with Joel M. Cohen, Brent Wible, Darryl Lew, Maria Beguiristain, Scott Hershman, Ladan Stewart, Michael Kendall, Lauren M. Papenhausen, David H. Lim, David E. Bond, Marietou Diouf, Gabriella Margaux Pérez Klein, and Robert DeNault).
A Vested Interest in Honest Business: California Attorney General Reminds Businesses that FCPA Violations Remain Actionable under State Law Amid Federal FCPA Enforcement Pause | White & Case LLP (co-author Darryl Lew, Tami Stark, and Marika Fain).
A new sheriff in town? No time for complacency as the US pauses anti corruption enforcement | White & Case LLP (co-author with Jonah Anderson, Darryl Lew, Neill Blundell, Joel M. Cohen, Kami Haeri, Xavier Hubert, Anneka Randhawa, Brent Wible, Marika Fain, and Phil Taylor).
The Guide to Multilateral Development Bank Investigations | White & Case LLP (co author with Dr. Daniel Zapf, Joel M. Cohen, Darryl Lew, Dr. Maximilian Clasmeier).
FCPA Freeze and Refocus: Is Enforcement Becoming a Tool to Promote U.S. Economic, Foreign Policy and National Security Interests? | White & Case LLP (co-author Joel M. Cohen, Darryl Lew, David H. Lim, Brent Wible, Maria Beguiristain, Tami Stark, Ladan Stewart, Marietou Diouf and Robert DeNault).
DOJ to Evaluate AI Risk Management and Whistleblower Protections in Corporate Compliance Programs Client Alert, October 2024 (co-author with Darryl Lew, Joel M. Cohen, Tami Stark, Marietou Diouf, Saambavi Mano).
DOJ Launches New Whistleblower Pilot Program, Client Alert, August 2024 (co-author with Darryl Lew, Tami Stark, Marika Fain).
SEC Warns Individual Actors of Potential Liability for AI-Related Security Risk Disclosure Failures, Client Alert, April 2024 (co-author with Darryl Lew, Joel M. Cohen, Maia Gez, Tami Stark, Marietou Diouf, Saambavi Mano).
Better, Stronger, Faster—DOJ's Approach to Cooperation and Remediation Under the Revised Corporate Enforcement and Voluntary Self-Disclosure Policy, Corporate Counsel, April 2024 (co-author with Darryl Lew and Nida Jafrani).
New Settlements Demonstrate the SEC's Ongoing Efforts to Hold Companies Accountable for AI-Washing, March 2024 (co-author with Darryl Lew, Joel M. Cohen, Tami Stark, Ladan Stewart, Marietou Diouf, Saambavi Mano).
DOJ Doubles Down on Warnings Against AI Misuse, Client Alert, March 2024 (co-author with Darryl Lew, Joel M. Cohen, Tami Stark, Marietou Diouf, Saambavi Mano).
DOJ Announces Pilot Program to Pay Monetary Rewards to Whistleblowers, Client Alert, March 2024 (co-author with Darryl Lew, Joel M. Cohen, Marietou Diouf, Marika Fain, Tami Stark).
2023 Global Compliance Risk Benchmarking Survey, June 2023. Authored in collaboration with KPMG, and with Darryl Lew, and Anneka Randhawa.
Proposed EU Anti-Corruption Directive – How Does It Compare to the US and UK Gold Standard? Client Alert, May 2023 (co-author with Darryl Lew, Anneka Randhawa, Daniel Zapf, Aleksandra Oziemska, Jean-Lou Salha, Ed Pearson, and Stephen Rowland).
The Framework or Cooperation between the European Public Prosecutor's Office and Non-EU Third Countries. Client Alert, October 2022. (co-author with Darryl Lew, Jean Pierre Picca, Karl Jörg Xylander, Jean-Lou Salha, Marika Fain).
"In Re Boeing emphasizes risk-based governance", September 2022, Global Investigations Review Americas Investigations Review (co-author with Darryl Lew).