Apurva Zutshi is a Partner at the Firm with over a decade of specialised focus on Anti-Corruption & Compliance, White Collar Crime and Investigations, Corporate Governance, Defence and Public Procurement, Mergers & Acquisitions and Corporate advisory.

Apurva’s experience includes conducting internal investigations into issues related to bribery and corruption, employee and third party fraud, conspiracy, embezzlement, conflict of interest, etc., including investigations having cross border implications under laws of multiple jurisdictions, such as the US FCPA and the UK Bribery Act, 2010. He regularly advises clients with respect to identification of risk areas, risk mitigation, review of forensic evidence, conducting interviews with senior management, corporate governance requirements, best practices and disclosure requirements under Indian laws. He has also advised clients on varied matters related to corporate governance, including advising boards and audit committees of listed companies.

As part of acquisition proposals, Apurva regularly advises and assists clients in conducting legal diligences for assessing compliances with legal requirements under anti-corruption, anti-money laundering and anti-fraud laws. He also assists clients post-acquisition implementation of comprehensive governance and compliance frameworks and testing of efficacy of such frameworks. As part of enhancing compliance measures at the workplace, he has also assisted clients in formulation and implementation of policies and procedures to prevent unethical behavior and has also conducted compliance training workshops for several officers and employees. He also often advises clients on compliance issues emanating from public and private procurement (including defence procurement).

Apurva has been recognized as a key lawyer, by the Legal 500 – Asia Pacific 2024 rankings for the Firm’s White Collar Crime practice. Apurva was the lead Associate for an internal investigation that was awarded the “IBLJ Star Deal of the Year Award 2020” by India Business Law Journal. Apurva regularly writes on issues related to anti-corruption and related compliance issues.

Select Experience Statement

Internal Investigations

• Undertook an internal investigation into whistle-blower allegations of fraud, conflict of interest and quid pro quo against the MD & CEO of a large listed Indian multinational bank, which culminated in termination of the individual and ongoing investigations by Indian enforcement agencies. The investigation involved structuring of the forensic review as part of the fact finding and document review process and periodic review of the forensic findings for streamlining the data recovery process. It further involved advising the audit committee on the steps to be taken at each stage of the investigation.

Corporate Governance & Board Advisory

• Assisted the board of directors of a leading listed Indian bank with respect to a review of the compliance measures undertaken by the bank in relation to whistleblower complaints received by it. Further, also advised the client with respect to remediation measures that may be undertaken to rectify the gaps in their compliance processes and procedures.

Compliance Diligence and Acquisitions

• Conduced anti-bribery and anti-corruption diligence for an American investment bank, in relation to its proposed investment into an Indian hospital chain and trained senior management of the target in relation to best practices related to anti-bribery and corporate governance.
• Assisted a leading Australian global financial services group in conducting an anti-bribery, anti-corruption and anti-money laundering legal diligence as part of an acquisition proposal in a leading Indian digital infrastructure services company.

Compliance Advisory

• A multinational spirits company on advice related to the coverage of attorney-client privilege in India and whether advice provided by Indian lawyers as part of an investigation can be called for as evidence by international enforcement agencies as part of an ongoing international investigation, in light of the applicable laws governing protection of privilege.

Compliance Audits/ Pro-Active Risk Assessments

• Assisted a Canadian fertilizers company in conducting a compliance audit on its exclusive authorized sales representative in India and suggesting remedial measures for implementation by the client, on the basis of a forensic review.

Compliance Programs, Policies & Trainings

• Assisted a south-east Asian venture capital fund with respect to drafting anti-bribery and anti-corruption policy, anti-money laundering policies and other related compliance policies for their portfolio companies.

A detailed experience statement can be shared on a confidential basis.

Professional Memberships

• Bar Council of India (2014)
• Bar Council of Delhi (2014)

Education

• B.B.A. (Hons), LL.B. (Hons), National Law University, Jodhpur (2014)