Rebecca Worthington’s practice focuses on litigation, investigations and white collar criminal defense. She has experience in defending cases brought under the False Claims Act (FCA) and representing clients in internal and government investigations, including matters involving economic sanctions, money laundering and the Bank Secrecy Act, and the Foreign Corrupt Practices Act (FCPA). She is a certified anti-money laundering specialist, and helps clients design and evaluate BSA/AML and sanctions compliance programs. For multiple years, Rebecca has been named a Washington DC Super Lawyers – Rising Star, among the top up-and-coming lawyers, defined as 40 years of age and younger or in the practice of law for less than 10 years.

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Due to the sensitive nature of Ms. Worthington’s work, much of it is not public. Some of her most notable nonconfidential work includes:

  • Assisting a large African nation, including its financial intelligence unit and AML/CFT regulatory bodies, prepare for, conduct, and respond to its Financial Action Task Force (FATF) mutual evaluation.
  • Representing a US company and its UK subsidiary in an OFAC investigation into apparent violations of the Iranian Transactions and Sanctions Regulations, resulting in a non-public cautionary letter and no finding of violation or monetary penalty.
  • Assisting in the representation of National Commercial Bank, Saudi Arabia’s largest bank, in defending and settling a multiyear OFAC investigation of apparent violations of US sanctions against Sudan and Syria.
  • Assisting in the representation of a global, MENA-based bank in defending and resolving a multiyear OFAC investigation with the issuance of a non-public no action letter.
  • Representing foreign financial institutions in investigations of potential violations of US sanctions and money laundering laws.
  • 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 company submitted claims for work that was not performed.
  • Representing a manufacturing company in an FCA complaint, alleging that the company falsely certified parts complied with NAVAIR standards.
  • Achieving dismissals in favor of a professional basketball player in two separate actions. In the first action, asserting various fraud and breach of contract claims, the motion to dismiss was granted by the federal district court with the US Court of Appeals for the District of Columbia Circuit upholding the dismissal. The second action, alleging that the basketball player defamed the same plaintiff based on an interview published in Sports Illustrated, was also dismissed by the federal district court on a motion for summary judgment.
  • Representing a federal government contractor in an FCA complaint, alleging that the company paid gratuities to influence the award of a government contract.
  • Serving as second chair in a jury trial in Virginia state court involving breach of contract claims, securing a favorable outcome for the client.
  • Drafting a successful demurrer in which the court dismissed, without leave to amend, an employment lawsuit alleging claims of intentional and negligent infliction of emotional distress.
  • Assisting, during a secondment with a client’s in-house counsel, with the review, renegotiation and revision of existing third-party contracts in anticipation of a corporate spinoff.
  • Serving as second chair in a jury trial in the Eastern District of Virginia, assisting throughout the case including discovery, motions practice and all phases of the trial. The jury returned a verdict completely in favor of the client, awarding it monetary damages for breach of contract and finding in favor of it on a counterclaim.
  • Assisting in drafting a successful motion to dismiss for lack of personal jurisdiction in a case based on the conspiracy theory of jurisdiction.
  • Drafting and arguing a successful opposition to a motion to dismiss in which the defendant claimed a later agreement superseded another contract at issue.


  • Duke University, J.D., articles editor, Duke Journal of Comparative & International Law, 2009
  • Vassar College, B.A., 2006


  • District of Columbia, 2010
  • Virginia, 2009


  • U.S. Ct. of App., Fourth Circuit
  • U.S. Ct. of App., District of Columbia Circuit
  • U.S. Dist. Ct., Dist. of Columbia
  • U.S. Dist. Ct., E. Dist. of Virginia
  • U.S. Dist. Ct., W. Dist. of Virginia
  • U.S. Supreme Court

Memberships & Affiliations

  • Member, Association of Certified Anti-Money Laundering Specialists
  • Member, the Women’s White Collar Defense Association
  • Best Lawyers: Ones to Watch in America 2024, Criminal Defense: White-Collar
  • Selected in the Inaugural 2023 50 Women to Watch List, Corporate Counsel Business Journal
  • IFLR Rising Stars Awards Americas 2020 winner (white collar crime)
  • Selected by peers as a Washington DC Rising Star, among the top up-and-coming lawyers in the region

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  • Panelist, “Lessons From Implementing the Anti-Money Laundering Act,” American Bar Association, January 2022.
  • Co-author, “A ‘C Plea’ and a Judge,” Fraud & Abuse, a publication of the American Health Lawyers Association, August 2018.
  • Co-author, “Amici Enter Supreme Court Fray About Reach of FCA,” Bloomberg BNA Heath Care Fraud Report, March 2016.
  • Co-author, “Global Business Fraud and the Law: Preventing and Remedying Fraud and Corruption,” Practising Law Institute, October 2015.
  • Co-author, “The Constitutional Clash Over the Fokker DPA,” Law360, July 2015.
  • Co-author, “Keeping Secrets Secret: A Primer on Economic Espionage,” Law360, September 2013.

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