Experience

• • OceanGate in investigations following the implosion of its Titan submersible during a Titanic expedition.
  • Multiple audit professionals in SEC investigations that resulted in declinations from the government.
  • A public company and an individual employee in a criminal FCPA investigation by DOJ.
  • A public tech company in an SEC-led FCPA investigation into conduct in Russia resulting in a complete declination.
  • A multinational company in a resolution with DOJ for providing material support to foreign terrorist organizations in Syria.
  • A Swiss financial institution in multiple DOJ criminal and civil enforcement matters.
  • A private equity firm in DOJ and SEC investigations regarding the provision of investment services to a sanctioned Russian oligarch.
  • A special committee of the Board of a public company in reviewing and advising on a sensitive matter.
  • A major sports league in a confidential investigation of a team’s compliance with league rules.
  • Trafigura, a multinational commodity trading company, in an FCPA resolution with DOJ related to conduct in Brazil.
  • A crypto trading platform in an investigation by the California Attorney General into its operations and disclosures.
  • A venture capital firm in relation to DOJ’s investigation of FTX and prosecution of Sam Bankman-Fried and others.
  • A hospitality company in a DOJ criminal investigation into tax violations.
  • A non-profit organization and its Board in a DOJ criminal bribery investigation.
  • The CEO and another top executive of a public company in a DOJ criminal investigation.
  • An oil company executive in a criminal FCPA investigation, resulting in DOJ agreeing not to bring any charges against client.
  • The President of a Brazilian foundation in a DOJ criminal money laundering, fraud, and corruption investigation.
  • A bank executive in a DOJ criminal wire fraud investigation.
  • Boeing in a settlement with the SEC over public statements regarding the 737 MAX.
  • Ernst & Young in an SEC settlement regarding misconduct in relating to ethics and continuing professional education training.
  • The former head trader at Archegos Capital Management in investigations and charges by the SDNY, SEC, and CFTC.
  • Riversource, an affiliate of Ameriprise, in responding to and settling an investigation from the SEC’s Division of Enforcement.
  • L&T Construction in a criminal investigation by the DOJ into alleged FCPA violations by individuals at a joint venture company.
  • A leading private equity firm in SEC and DOJ investigations concerning employees’ personal investments.
  • Robinhood in its SEC and FINRA settlements relating to best execution practices and payment for order flow.
  • The Audit Committee of Mobile Telesystems, a Russian telecommunications company, in an investigation relating to its Uzbek subsidiary and subsequent advice relating to the Company’s Deferred Prosecution Agreement with DOJ and settlement with the SEC.
  • Capital One in a resolution with FinCEN regarding its AML program, without criminal charges being filed.
  • Toyota Motor Corp. in a resolution with the Department of Justice and Environmental Protection Agency regarding its emissions reporting practices, without any criminal charges being filed.
  • Société Générale in securing a deferred prosecution agreement and first coordinated resolution between the DOJ and France’s Parquet National Financier regarding claims of potential corruption of foreign officials in Libya.
  • Ripple in a ruling against the SEC in the SDNY holding that Ripple’s digital token XRP is not a security or “investment contract” in many circumstances.
  • Rolls-Royce in an internal investigation and coordinated resolutions with UK, U.S. and Brazil investigating authorities relating to bribery and corruption involving intermediaries in a number of overseas markets.
  • Keppel Offshore & Marine in an internal investigation and coordinated resolutions with the U.S., Brazilian and Singaporean criminal authorities in relation to corrupt payments to Petrobras and other Brazilian officials.
  • Twitter in Department of Justice and Congressional investigations into Russian interference in the 2016 presidential election.
  • Habib Bank in litigation and a negotiated settlement with the NYDFS relating to AML/BSA compliance and assisting Habib in winding down the business of their NY branch.
  • Toyota Motor Sales USA in various state and federal investigations relating to vehicle acceleration issues. These included 29 state attorney general investigations, congressional inquiries, SEC investigations, and Department of Justice (DOJ) investigations, all of which settled without any criminal convictions for the company.
  • Bank Hapoalim in a cross-border tax investigation by the United States Department of Justice, Federal Reserve, and New York Department of Financial Services.
  • Rolls-Royce in its leniency agreement with Brazil’s Office of the Comptroller General.
  • A Central and Eastern European-based international manufacturer in a corruption investigation and associated criminal proceedings relating to its subsidiaries in Eastern Europe.
  • A multinational oilfield services company in allegations relating to potential impropriety in Russia.
  • A large Spanish-based manufacturing company in a post-acquisition compliance integration project, involving review of global sales intermediaries in over 40 jurisdictions.
  • An international oil company in an internal investigation into allegations of corruption and embezzlement in relation to awards of local contracts in Kazakhstan.
  • A Europe-based marine and power generation equipment manufacturer in a review of its internal compliance systems and controls.
  • A multinational life sciences company in internal investigations relating to allegation of corruption at subsidiaries in Russia and Ukraine.
  • Board of a major financial institution in responding to inquiries from the U.S. House Financial Services Committee.
  • A hedge fund in allegations of market abuse (disclosure of inside information), including responding to regulatory requests and conducting a cross-border internal investigation.
  • A major automobile manufacturer in response to bribery and corruption concerns brought by various U.S. federal agencies.
  • A multinational publicly traded company and an international media conglomerate in FCPA advice and internal investigations arising out of the FIFA investigations.
  • An international construction company in an internal investigation of alleged bribery in Latin America.
  • FanDuel in a review of the company’s internal controls, standards, and practices.
  • A leading pharmaceutical company in investigating possible FCPA violations in several countries around the world, including Nigeria, Venezuela, and Ecuador.
  • KKR in its settlement with the SEC concerning the allocation of broken deal expenses.
  • A major international bank in responding to an investigation into its auto lending and securitization business.
  • A leading private equity firm in an SEC inquiry concerning the allocation of legal expenses and settlement amount to client funds in a private antitrust case.
  • JPMorgan Chase & Co. in federal and state investigations of mortgage servicing, foreclosure and origination related issues, including relating to the $25 billion settlement with DOJ, State Attorneys General and other federal authorities, and in SEC and other regulatory investigations relating to the issuance of RMBS securities.
  • JPMorgan Chase Bank, N.A. in investigations by several State Attorneys General and a federal regulator into credit card collections and debt sale practices.
  • Four separate Swiss banks in the DOJ’s program designed to encourage Swiss banks to cooperate in the DOJ’s investigations of the use of foreign bank accounts to commit tax evasion.
  • A leading investment management firm in a non-public investigation by the SEC.
  • A financial institution in a DOJ investigation of potential corruption associated with investments by a Middle Eastern sovereign wealth fund.
  • Siemens’ Audit Committee in a worldwide investigation into possible corrupt payments to government officials leading to an early settlement with the U.S. and German authorities.
  • A national bank in an anti-money laundering investigation by New York authorities.
  • A Fortune 100 company in civil and criminal investigations regarding possible FCPA violations, resulting in both the DOJ and SEC closing their investigations without bringing any charges or seeking any penalties.
  • A leading natural resources group in its criminal investigation by the SFO into allegations of fraud, bribery and corruption relating to the activities of the company or its subsidiaries in Kazakhstan and Africa.
  • The Audit Committee of a Chinese pharmaceutical manufacturer that is publicly listed in the U.S. in an investigation of potential corruption issues arising under the FCPA.
  • A major global financial institution in federal and state regulatory investigations relating to auction-rate securities.
  • A leading multinational candy and confections manufacturer in responding to allegations that employees in one of the company’s overseas subsidiaries were making charitable donations in return for favorable action by local government officials.
  • A major consumer products company in an investigation into the use of third parties in Southeast Asia.
  • Ferrostaal, a global provider of industrial services in plant construction and engineering, in an extensive internal compliance investigation relating to allegations of corruption and other wrongdoing in several jurisdictions.
  • A Special Committee of the Board of Directors of Merck, charged with conducting an internal investigation of the Company’s conduct in the development and marketing of Vioxx.
  • A leading international pharmaceutical company in an FCPA investigation in Europe relating to marketing practices.
  • ACE Bermuda in investigations by various state attorney generals, insurance departments and the SEC, alleging antitrust violations and improper broker compensations, business placement and financial statement practices; allegations resulting in shareholder derivative and class action litigation.
  • Universal Music Group in the New York State Attorney General’s investigation of radio promotion practices.
  • Forest Laboratories and Forest Pharmaceuticals in the settlement of civil and criminal investigations led by the United States Department of Justice and the United States Attorney’s Office for the District of Massachusetts, and related civil qui tam litigation, regarding marketing, promotional and other activities for its products Celexa, Lexapro and Levothroid.
  • Bank of New York in a U.S. Department of Justice investigation into allegations of money-laundering and deficient AML controls, as well as other Bank Secrecy Act issues.
  • An internal review for the Audit Committee of BG Group relating to issues arising in an investigation by Italian authorities into allegations of corruption in a project in Brindisi, Italy.
  • An internal investigation of a multinational insurance company in simultaneous investigations by more than 15 U.S. federal and state regulators, including the New York Attorney General, the SEC, state attorneys general and state insurance departments alleging improper broker compensation, business placement, and financial statement practices.
  • A Russian high-net-worth individual in public allegations and assistance with responding to related inquiries.
  • The former U.S. Deputy Attorney General and Acting Attorney General in Congressional investigations related to Russian interference in the 2016 presidential election.
  • Independent directors of News Corporation in allegations relating to phone-hacking in the United Kingdom.
  • Individuals in a challenge to a Crown Court Order freezing their assets at the request of a Middle Eastern government in the context of a multi-jurisdictional criminal investigation. The case, which was considered by the Court of Appeal, involved issues of principle relating to the standard of evidence in asset freezing orders at the request of foreign states, as well as the impact of misinformation by the requesting foreign authorities.
  • Numerous employees on the FX Spot Desk in New York and London in ongoing investigations by, among others, the DOJ and FCA.
  • A Bermudian physician in a successful challenge to his arrest and the search of his home before the Bermuda Supreme Court, upheld by the Bermuda Court of Appeal.
  • Kenneth D. Lewis, former CEO of Bank of America, in regulatory matters relating to the Merrill Lynch acquisition, including defense against civil claims brought by the New York Attorney General and various civil securities and derivative cases.
  • Léo Apotheker, former CEO of Hewlett-Packard Company, in securities class actions, derivative litigation and regulatory inquiries arising from HP’s acquisition of Autonomy.
  • The former global head of structured-products ABS collateralized debt obligations at a major investment bank in an SEC inquiry into the offering of notes in a synthetic CDO.
  • The former Chief Financial Officer of AOL Time Warner in an SEC investigation into AOL’s advertising revenues.