Dr. Richard 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.
Richard has substantive experience with conducting cross-border white collar investigations, specifically in the context of multi-jurisdictional investigations related to the FCPA, anti-money laundering, fraud, compliance violations, whistleblower complaints, export/import regulations, sanctions violations, tax, technical compliance among other legal and regulatory issues.
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.” One market participant says he is “(…) very responsive. Thinks ahead and provides business-related information on innovations. Makes binding, practical statements.”
He has published widely, including in the Corporate Compliance Law Journal (CCZ) and is regularly invited to comment on global trade and compliance issues, including recently on regulatory developments in 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-author of the International Comparative Legal Guide to Sanctions (2022). He is also the author of Foreign Mining Investment Law (2016), which includes CSR considerations that are now often referred to as ESG-related.
Before joining Willkie, 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.
In 2018, Richard worked in Washington, D.C. where he assisted clients in overcoming the challenges arising from the divergence between US and EU economic and financial sanctions. Most recently, he worked as of counsel in the International Trade, White Collar Defense & Investigation and ESG practice groups at a renowned US law firm.
He also is regularly invited to speak on and contribute to compliance-related matters, including most recently for the Financial Crime Academy, where his team created the Certificate Course on Sanctions & Export Control Compliance. Richard is a member of the German Institute for Compliance e.V. (DICO) and Ethics & Compliance Switzerland.
Richard speaks German, English, Spanish, and French.
Experience
- The Legal 500 Germany / EMEA, recommended in the category of Foreign Trade Law.
Publications
- “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.
- Association of Austrian In-House Counsel (VUJ) Event: Sanctions against Russia – January 26, 2023 in Vienna, Austria
- German Institute for Compliance (DICO) Webcast: Technology transfer in the area of Export Controls – May 6, 2021
- German-Russian Chamber of Commerce Abroad (AHK): Background discussion on sanctions – May 26, 2020
- University of Trento, Innsbruck and Bozen/Bolzano (Euregio Mobility IV Project): EU Sanctions against the Russian Federation and the Islamic Republic of Iran in a comparative perspective International Conference (“The European Union blocking statute and Instex”) – September 20, 2019
- 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
- Webinar Financial Crime Academy on the subject of the Supply Chain Due Diligence Act, June 2023
Richard has advised on the following selected significant matters:*
- Advising Wendel and other shareholders on the sale of Constantia Flexibles to One Rock Capital Partners
- Assisting a major German company in its internal investigation into alleged misconduct by key social media influencers
- Advising a European manufacturer of luxury vehicles in relation to ESG-related requirements with a specific focus on compliance with the German Supply Chain Due Diligence Act
- Advising a leading international manufacturer of medical science equipment on compliance with EU Russian & Crimea Sanctions
- Advising a leading global technology company on updating the existing screening process of business partners and products in relation to the export of (US) goods from the European Union to China
- Advising a client in business partner due diligence, including enhanced background checks
- Setting up a state-of-the-art ESG compliance management system for a world leader in medical and scientific education solutions
- 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 for contemplated exports to China
- Advising a listed advertising company headquartered in the U.S. with respect to compliance with EU sanctions and AML risks under the German law
- Advising a global food manufacturer in connection with compliance with the new requirements of the EU Whistleblower Directive
- Advising an Austrian 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
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