Zeno, Thomas E.

Thomas E. Zeno

Of Counsel

Thomas Zeno has more than 25 years of experience in the US Attorney’s Office for the District of Columbia. During that time, Tom investigated and prosecuted economic crimes involving healthcare, financial institutions, credit cards, computers, identity theft and copyrighted materials. As the office’s Healthcare Fraud Coordinator for the last eight years, Tom supervised investigation strategies of agents from the Federal Bureau of Investigation, the Department of Health and Human Services, the Drug Enforcement Administration and the Medicaid Fraud Control Unit regarding healthcare offenses. He also served as the liaison with the office’s civil division on joint proceedings. In addition, Tom served for several years as the Executive Assistant US Attorney for Operations, where he helped supervise the criminal division of the office.

Tom’s significant prosecutions include the conviction of five codefendants accused of defrauding an integrated managed care consortium and the criminal portion of a global settlement by a pharmaceutical company for off-label marketing. Tom also has been involved in highly publicized matters including hearings related to the conditions of release for John Hinckley, Jr., attempted presidential assassin, and the prosecution of government officials.

Tom represents companies, financial institutions, audit committees, medical providers and individuals by conducting internal investigations and defending against government investigations under the False Claims Act (qui tam), sanctions enforced by the Office of Foreign Assets Control (OFAC) and the Foreign Corrupt Practices Act (FCPA). Tom evaluates these actions through the lens of his extensive experience both as a supervisor as well as a line attorney who handled investigations personally by litigating scores of trials and contested hearings. His insight and judgment make him a powerful advocate when explaining flaws in qui tam or FCPA actions to investigators from the government such as the Department of Justice and Office of the Inspector General.

Tom is the recipient of several commendations and special achievement awards given by the Department of Justice and was awarded Investigation of the Year, Honorable Mention by the National Healthcare Anti-Fraud Association in 2008. In 1998, he received the Harold J. Sullivan Award, the highest award presented annually by the Assistant United States Attorneys’ Association for career excellence. In 2007, he was awarded the Inspector General’s Integrity Award from the Department of Health and Human Services for his outstanding contributions in healthcare fraud investigations.

Tom is co-editor of the book and co-author of two chapters in Global Business Fraud and the Law: Preventing and Remedying Fraud and Corruption. The 2015 book, published by PLI, presents a comprehensive and practical guide to preventing business fraud and corruption, and remedying unlawful behavior should it occur.  
Tom was a panelist analyzing the need for data security by organizations at the 28th Annual Corporate Law Center Symposium presented by the University of Cincinnati College of Law in 2015.

Tom is the co-author of articles on preventing and responding to data breaches published in 2014 in Title News and online in Baseline Magazine, as well as “Preserving the Attorney-Client Privilege for In-House Counsel,” published in the December 2013 edition of Connections, the American Health Lawyers Association Magazine, “Uncle Sam Becomes a Doctor: Government Challenges to Medical Necessity,” published in the Bar Journal of the Cleveland Metropolitan Bar Association in September 2013 and "Rx for Health Care Fraud: The Feds Get Personal,” published in Criminal Justice, Winter 2012, by the American Bar Association. 

Tom served as a panelist for the 19th Sentencing Guidelines Seminar presented by the National Association of Criminal Defense Lawyers and the American Bar Association in 2010. He also authored “A Prosecutor’s View of the Sentencing Guidelines,” published in Federal Probation.

As an adjunct professor at Georgetown University for eight years, Tom instructed student prosecutors in trial skills at the Criminal Justice Clinic. 


  • Representing a physician-owned joint venture during a federal qui tam investigation that ended following a presentation made to the government resulting in declination by the government and dismissal by the relator. Neither a settlement nor a Corporate Integrity Agreement was required. 
  • Representing an airplane parts manufacturer during a federal qui tam investigation that resulted in declination by the government and dismissal by the relators. Neither a settlement nor a Corporate Integrity Agreement was required. 
  • Representing a government employee by persuading the government to dismiss all eight charges in a federal indictment the week before trial, including charges of computer hacking, theft and making false statements.  
  • Representing a federal government contractor by successfully resolving a relator’s false claims act complaint that the company paid gratuities to influence award of a government contract. 
  • Representing the Audit Committee of a China-based US public company and performing an independent investigation concerning the FCPA and financial disclosures to the US Securities and Exchange Commission (SEC). 
  • Representing a manufacturing company by successfully resolving qui tam litigation alleging that the company falsely certified parts complied with NAVAIR standards.
  • Representing government employees by securing dismissal of the complaint suing them in their individual capacity under the Bivens doctrine for alleged violations of constitutional rights.
  • Representing a former employee of a government contractor during parallel criminal and civil investigations (including grand jury testimony) following a federal qui tam complaint alleging that the former employer submitted claims for work that was not performed.
  • Representing individuals by securing dismissal of more than 40 felony charges and return of all personal funds that had been seized in the largest case of its kind in Florida, involving the arrest of more than 50 people affiliated with Allied Veterans of the World who were accused of RICO violations, money laundering and illegal possession of slot machines following an investigation that lead to the resignation of the Florida Lieutenant Governor. 
  • Representing a former manager during questioning about billing practices by federal and state healthcare investigators under a common interest agreement with the former employer, a healthcare provider. 
  • Representing an individual who received a substantial downward variance after pleading guilty to healthcare fraud. 


  • Georgetown University, J.D., cum laude, American Criminal Law Review, 1979
  • Xavier University, B.A., summa cum laude, 1974


  • District of Columbia, 1981
  • Ohio, 2012


  • U.S. Ct. of App., District of Columbia Circuit
  • U.S. Dist. Ct., Dist. of Columbia
  • U.S. Dist. Ct., S. Dist. of Ohio

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