Dr. Richard W. Roeder heads the German Investigations & Enforcement, Global Trade & Investment and White-Collar Defense practices and is a member of the Environmental, Social & Governance practice group.
He assists clients in navigating the ever-changing and increasingly fragmented regulatory landscape with a focus on sanctions, export controls, ESG/supply chain, AML and ABC compliance.
He is a renowned practitioner in the field of foreign trade compliance with a focus on navigating the divide between conflicting regulatory requirements of the U.S., the EU and China. He has been recommended as top lawyer in the category foreign trade law by German Newsweek and the Lexology Index (formerly Who's Who Legal). Legal 500 Germany / The Legal 500 EMEA recommend Richard in the category Foreign Trade Law and highlight that he “is a key contact for economic and financial sanctions as well as export control issues” and “makes binding, practical statements.”
Richard has substantive experience with conducting cross-border white collar investigations, specifically in a multi-jurisdictional context and relating to alleged violations of financial and economic sanctions, export controls, anti-bribery, anti-money laundering, (internal) fraud and whistleblower complaints, among other legal and regulatory issues.
Richard is a Certified Compliance Officer (Bucerius Law School) and has published widely, including in the German Corporate Compliance Law Journal (CCZ) and the New Journal for Economic, Tax and Corporate Criminal Law (NZWiSt). He is regularly invited to comment on global trade and compliance issues, including on regulatory developments in the U.S., China and the consequences of the Ukraine crisis.
He is co-author of “U.S., EU, and UN Sanctions: Navigating the Divide for International Business” (2019) and co-authored the International Comparative Legal Guide to Sanctions (2020). He is also the author of Foreign Mining Investment Law (2016), which includes CSR considerations that are now often referred to as ESG-related. He also is regularly invited to speak on and contribute to compliance-related matters, including at the German Institute for Compliance e.V. (DICO).
Before pursuing his legal career, he was a scholarship holder of what is now known as the Mercator Fellowship on International Affairs and worked for the Federal Ministry of Economics in Berlin, the German Foreign Service in Caracas, Venezuela, the European Union in Damascus, Syria and the United Nations Development Program in Geneva, Switzerland.
Prior to joining Willkie, Richard worked in the International Trade, White Collar Defense & Investigation and ESG practice groups at a renowned US law firm, including in Washington, D.C., where he assisted clients in overcoming the challenges arising from the divergence between US, Chinese and EU economic and financial sanctions.
Richard speaks German, English, Spanish, and French.
Experience
- German Newsweek, recommended as Top Lawyer in the category Foreign Trade Law
- Legal 500 Germany / EMEA, recommended in the category Foreign Trade Law
- WWL Ranking in Lexology, recommended in the category Germany - Trade & Customs
Publications
- “Zur Haftungsbeschränkung eines Gesellschaftsorgans durch interne Zuständigkeitsregelungen”, New Journal for Commercial, Tax and Corporate Criminal Law (NZWiST) 2024, Issue 7/2024, p. 268-271
- “Anonyme Anzeige über Hinweisgebersystem als Basis einer Durchsuchungsanordnung”, Corporate Compliance Law Journal (CCZ) 2024, Issue 6/2024, p. 183-184
- “EU-Unternehmen kann seiner Rückzahlungsverpflichtung an Unternehmen mit Iranbezug keinen eigenen Verstoß gegen Iran-Sanktionen entgegenhalten”, Corporate Compliance Law Journal (CCZ) 2024, Issue 4/2024, p. 118-120
- “One Step Closer to the EU Corporate Sustainability Due Diligence Directive”, February 5, 2024.
- “German Federal Court of Justice Confirms: Liability of a Managing Director for Compliance Violations Can Be Limited by Internal Allocation of Responsibilities”, February 2, 2024.
- “Compliance (Due Diligence) im Kontext von Transaktionen – Die ESG Due Diligence”, Corporate Compliance Law Journal (CCZ) 2023, Issue 1-2/2024, p. 13.
- “Compliance (Due Diligence) im Kontext von Transaktionen – Außenwirtschaftsrecht”, Corporate Compliance Law Journal (CCZ) 2023, Issue 12/2023, p. 337.
- “Compliance (Due Diligence) im Kontext von Transaktionen – Anti-Bribery/Corruption”, Corporate Compliance Law Journal (CCZ) 2023, Issue 11/2023, p. 310.
- “Hinreichender Tatverdacht für Anklageerhebung”, Corporate Compliance Law Journal (CCZ) 2023, Issue 10/2023, p. 287
- “Compliance (Due Diligence) im Kontext von Transaktionen – Allgemeine Einführung in die Thematik”, Corporate Compliance Law Journal (CCZ) 2023, Issue 10/2023, p. 269
- “EuGH-Vorlage zur Auslegung der VO (EG) Nr. 194/2008 v. 25. Februar 2008 im Rahmen einer möglichen Strafbarkeit nach dem AWG wegen Einfuhr von Teakholz aus Myanmar”, Corporate Compliance Law Journal (CCZ) 2023, Issue 9/2023, p. 252
- “KYS & KYC - (Un-)Intended Interplay Between the German Supply Chain Due Diligence Act and Anti-Money Laundering Laws?”, September 1, 2023
- “Anforderungen an einen Durchsuchungsbeschluss bei einer obersten Bundesbehörde”, Corporate Compliance Law Journal (CCZ) 2023, Issue 7-8/2023, p. 236
- “Selbstreinigung durch Compliance-Maßnahmen reduziert Geldbuße nach § 30 Abs. 1 OWiG”, Corporate Compliance Law Journal (CCZ) 2023, Issue 6/2023, p. 199
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“Toothless Tiger No More? Germany Strengthens Sanctions and AML Enforcement”, January 24, 2023.
- 8th Round of EU Sanctions Against Russia Affects a Variety of Actors in the Oil Shipping Industry and Providers of Related Services, October 13, 2022.
- “International Comparative Legal Guide to Sanctions” (2022).
- “The European Union Whistleblowing Initiative Whitepaper” (2021).
- “U.S., EU, and UN Sanctions: Navigating the Divide for International Business” (2019).
- “Foreign Mining Investment Law” (2016).
Speaking Engagements
Richard is regularly called to comment on global trade and compliance-related topics, including recently on the regulatory developments in China and those resulting from the Ukraine Crisis.
- Willkie Compliance Breakfast: ESG Reporting – October 24, 2024
- Willkie Compliance Breakfast: Early Case Assessment – July 18, 2024
- VDB Compliance Workshop: “All Crimes Approach” to Money Laundering: New Challenges for Railway Industry Companies – April 25, 2024
- ASW Nord Webinar: Pre-Employment Screening – April 10, 2024
- German Institute for Compliance (DICO) Forum: Export Controls and Sanctions due to Human Rights or other ESG Violations – September 27, 2023
- Webinar Financial Crime Academy on the subject of the Supply Chain Due Diligence Act, June 2023
- German Compliance Conference 2023 in Frankfurt/Main: Compliance meets Cyber Incident Responses - How companies can respond to cyber-attacks and which legal pitfalls to watch out for in the worst case
- Association of Austrian In-House Counsel (VUJ) Event: Sanctions against Russia – January 26, 2023 in Vienna, Austria
Richard has advised on the following selected significant matters:
- Advising national and international companies on internal investigations into alleged misconduct of management, employees and third parties
- Setting up state-of-the-art compliance management systems for national and international companies including in the field of healthcare, packaging and others
- Advising clients in business partner due diligence, including with enhanced background checks
- Advising a global food manufacturer in connection with compliance with the new requirements of the EU Whistleblower Directive
- Assisting a leading global technology company in enhancing its Internal Compliance Program including the implementation of a tailored international trade procedure
- Advising a leading international manufacturer of medical science equipment on compliance with EU Economic and Financial Sanctions and Export Controls
- Advising a market-leading multinational company for filter products and solutions on EU sanctions compliance
- Advising a leading German supplier of process and packaging solutions on ensuring foreign trade law compliance
- Advising a European packaging manufacturer on the analysis of its internal compliance program, in particular with regard to the changing regulatory landscape resulting from the Ukraine Crisis
- Advising an international company in the field of transport, trade and distribution of oil products and petrochemicals on compliance with sanctions in the context of the price cap for Russian oil and oil products
- Advising a leading US power solutions manufacturer in the automotive industry on its compliance with the EU’s new Regulation on Deforestation-free Products (EUDR) requirements
- Setting up a state-of-the-art ESG compliance management system for a world leader in medical and scientific education solutions
- Advising a European car manufacturer in relation to ESG-related requirements with a specific focus on compliance with the German Supply Chain Due Diligence Act
- Advising on transactional compliance risk assessments in the course of various M&A and private equity transactions
Credentials
Education
University of Cologne, Dr. jur., 2015 University of Queensland, Master, 2013 University of California, Berkeley, LL.M., 2011 Bucerius Law School, Law Degree, 2007