Government Investigations & White Collar

Our global Anticorruption and Foreign Corrupt Practices Act (FCPA) team works with clients to create and implement cross-border solutions that address issues around the anticorruption laws embodied in the FCPA, UK Bribery Act (UKBA), Organization for Economic Cooperation and Development (OECD) Convention, Inter-American Convention Against Corruption, Council of Europe Criminal and Civil Law Conventions, and the UN Convention Against Corruption.

We help our clients comply with global anticorruption laws and regulations to mitigate their risks and minimize their exposure to government investigations, prosecutions and derivative litigation. For example, we advise our clients on how to implement and maintain robust anticorruption compliance programs, including policies and procedures and internal controls. We also conduct internal investigations around the world and represent clients in proceedings involving US and foreign enforcement agencies. In addition, we counsel clients on their rights as victims of FCPA violations, and their potential entitlement to recover funds, including under the Crime Victims’ Rights Act (CVRA) and the Mandatory Victim Restitution Act (MVRA), as well as advising on broader financial crime issues, including obligations under the Dodd-Frank Act, Sarbanes-Oxley Act, and economic sanctions.

Our Anticorruption and FCPA team members are located throughout our global footprint. In the US, our team includes former federal prosecutors from various offices within the US Department of Justice (DOJ), along with former US attorneys and assistant US attorneys, all of whom have extensive experience with anticorruption and FCPA investigations and proceedings before the DOJ and the Securities & Exchange Commission (SEC). Our US colleagues also regularly advise clients on anticorruption and FCPA issues arising out of Latin America.

In the UK, we have advised on numerous bribery and corruption cases over the last 10 years. Our British team has significant expertise in conducting internal investigations, defending clients facing government investigations and prosecutions, and advising on self-reporting. The team includes a former Serious Fraud Office (SFO) and Financial Services Authority (FSA) (as it then was) prosecutor. We have assisted multinational corporates with the design, implementation and testing of their anti-bribery and anti-money laundering policies and procedures. Our colleagues in the EU are well-versed with the various anticorruption laws of the EU member states.

In the Asia Pacific region, our team has extensive knowledge of the anticorruption laws and regulations of Australia, Singapore, the People’s Republic of China, Hong Kong, and Japan.

Our Dubai-based Middle East team regularly conducts internal investigations into alleged misconduct and international investigations into alleged noncompliance by foreign agents and business partners, as well as compliance assessments to identify deficiencies or conduct issues that could give rise to enforcement liability, and remediation projects to resolve gaps, operationalize policies, and mitigate risks to business operations. In addition, our Middle East team has also counseled clients in major FCPA and UKBA representations in countless countries across the Gulf Cooperation Council (GCC), the Levant, and Africa and Asia.

Depending on clients’ global needs, we can call upon our lawyers who are resident in specific countries, fluent in the native languages and familiar with the local laws and jurisdictions.

Our Capabilities

We provide the following full range of anticorruption services:

• Risk assessment

• Compliance program gap analyses

• Preparing and implementing anticorruption compliance policies and training

• Due diligence on third parties, joint venture (JV) partners, and mergers and acquisitions (M&A) targets

• Audits

• Internal investigations

• Contract representations, warranties language, indemnification and audit rights

• Defense of enforcement proceedings brought by the DOJ, SEC, SFO, and other foreign enforcement agencies

• Voluntary disclosures

• DOJ opinion requests

• Assessment and litigation of claims for restitution under applicable statutes

Representative Experience

• Multinational corporation in the oil and gas industry – Serving on the FCPA compliance monitor team for this company in connection with a deferred prosecution agreement (DPA) and settlement agreement with the DOJ and SEC, and conducting independent compliance reviews of the company’s operations in Africa and Asia.

• Latin American state-owned energy companies – Represented multiple state-owned energy companies in seeking to be declared victims of FCPA violations and to obtain restitution under US law.

• Europe-based multinational infrastructure company – Conducted a global internal investigation and defended the company in a multiyear, global FCPA investigation resulting in one of the most significant FCPA resolutions to date.

• NYSE-listed company – Conducting an investigation on behalf of our client in response to whistleblower allegations at its Russia-based subsidiary concerning the FCPA, UKBA and local tax laws.

• China-based US public company – Representing the audit committee and performing an independent investigation concerning the FCPA and SEC financial disclosures.

• NYSE-listed company – Investigating of potential FCPA violations at locations in Mexico.

• Fortune 500 companies – Representation in conducting FCPA due diligence in global M&A and joint ventures.

• Publicly traded US-based wholesale electricity supplier – Representing this client, with substantial renewable energy assets, in an anticorruption investigation in Spain.

• Fortune 500 companies – Representing in FCPA internal investigations in Brazil, China, the Dominican Republic, Greece, Honduras, Italy, Poland, Russia, Spain and Venezuela, including revising and drafting corporate FCPA compliance and integrity codes.

• Global equipment manufacturer and distributor – Advising a global manufacturer and distributor of industrial equipment with FCPA/anticorruption matters. We created an internal audit program focused on controls for FCPA/anticorruption, and worked with its internal audit department in auditing the controls of the company in Latin America and Europe. We also conducted FCPA/anticorruption training in numerous countries, including Brazil, Poland, Russia and Germany.

• Various Latin America clients – Assisting in the review and revision of anticorruption policies and procedures and advising Brazilian entities on FCPA/anticorruption compliance, including company practices, internal compliance programs, human resources concerns and remedial measures for improving compliance.

• Fortune 500 companies – Training employees, as well as compliance-, auditing- and legal-staff on FCPA, UKBA and anticorruption laws and compliance.

• US public company – Conducting anticorruption training in the native language in multiple countries.

• Global telecommunications company – Counseling audit committee in connection with a worldwide white collar crime investigation into possible corrupt payments to government officials, which led to an early settlement of approximately US$1.6 billion.

• Global medical devices and therapy company – Advising with respect to six separate FCPA and UKBA inquiries in India, including conducting internal and key distributor investigations into alleged improper payments to government health care professionals, advising on the development of the company's internal business conduct standards and third-party compliance procedures, and reporting to the DOJ and SEC as to the same (resulting in a formal declination).

• World’s largest retail corporation – Counseling on several FCPA and UKBA inquiries in India, including conducting internal investigations into alleged improper payments and alleged issuance of improper benefits to government officials, and reporting to the DOJ and SEC as to the same.

• Member of ruling family Emirate of Dubai – Advising following an internal investigation touching upon the motorsport industry and Brazil.

• International pharmaceutical company – Counseling regarding an FCPA and UKBA inquiry in Iraq, including conducting internal and key distributor investigations into alleged improper payments to government health care professionals.

• International metals company – Advising on the voluntary disclosure to the DOJ and SEC of alleged improper payments made to government officials in Bahrain.

• Multinational technology and consulting corporation – Advising on three separate and distinct FCPA and UKBA inquiries in Algeria and Tunisia, including conducting internal investigations into alleged improper payments to government officials.

• Global oilfield product-manufacturing entity – Advising with respect to FCPA-related due diligence on a host of its foreign agents and business partners operating across the Middle East and North Africa (MENA) and Levant Regions.

• Worldwide industrial services and engineered solutions company – Advising with respect to FCPA and UKBA issues in the Kingdom of Saudi Arabia, including advising on the development of the company's existing internal compliance controls and the creation and implementation of supplemental anticorruption compliance program components.

We have deep experience advising clients on US and international anti-money laundering and countering the financing of terrorism (AML/CFT) requirements, including the US Bank Secrecy Act (BSA) and the BSA’s implementing regulations. Our team creates, assesses and enhances BSA/AML compliance programs; conducts internal investigations into potential BSA/AML violations and advises on corresponding remedial measures; and vigorously defends financial institutions and other entities in regulatory and enforcement actions alleging BSA/AML violations.

Financial services companies must address constantly evolving illicit finance threats, vulnerabilities and risks, alongside new BSA requirements and developments, and increased government interest in ensuring BSA/AML compliance. We routinely advise financial institutions on the BSA and help clients ensure that their AML/CFT compliance programs fully comply with the BSA and meet or exceed AML/CFT best practices. This includes conducting BSA compliance program reviews; providing training and drafting policies and procedures; analyzing potential customers, products and services for AML/CFT risks; and advising on new legislation, regulations and law enforcement priorities. Our team includes certified anti-money laundering specialists and lawyers that have previously served in the Department of Justice and Department of the Treasury, including the Financial Crimes Enforcement Network (FinCEN).

Our defense work includes representing financial institutions in examination responses and criminal and regulatory BSA/AML investigations and enforcement actions. We have experience representing financial institutions in matters before both state and federal agencies, including the Department of Justice, Department of the Treasury, the Federal Deposit Insurance Corporation (FDIC), the Federal Reserve and the New York State Department of Financial Services (DFS). We also assist financial institutions that must undertake remedial measures or program reviews required by consent orders, settlements or other agreements with government agencies.

As part of our firm’s global footprint, our AML/CFT work goes beyond the BSA, as we routinely advise non-US financial institutions and other entities regarding AML/CFT requirements. This work includes assessing compliance with AML/CFT international standards and best practices, including those set by the Financial Action Task Force (FATF), the Basel Committee on Banking Supervision and the Wolfsberg Group. Our FATF work includes conducting compliance gap analyses to ensure that financial institutions’ AML/CFT programs meet FATF’s standards. We also advise stakeholders, including both government and private sector entities, that are preparing for, undergoing or responding to FATF mutual evaluations. Additionally, we represent non-US financial institutions in regulatory and enforcement matters brought by the UK Financial Conduct Authority, as well as local central banks and regulators.

In partnership with our market-leading Public Policy Practice, we also advise clients regarding pending and contemplated statutory and regulatory developments that potentially impact their BSA/AML/CFT obligations and, when appropriate, can work with those clients to engage decision makers regarding these potential developments, particularly in Washington DC and Brussels.

Relevant Experience

• Supervised remediation efforts under a DFS consent order for a global financial institution relating to its AML and sanctions compliance programs.

• Assisted a large African nation, including its financial intelligence unit and AML/CFT regulatory bodies, prepare for, conduct, and respond to its FATF mutual evaluation.

• Conducted anti-money laundering and sanctions risk assessment for a large multinational financial services company in preparation for its home country FATF mutual evaluation, including advising the company on improvements to its existing financial crime controls.

• Advised a regional bank on BSA/AML and sanctions matters related to loans, trade finance and customer due diligence.

• Conducted multijurisdictional sanctions and AML/CFT compliance program assessment across the Middle East and Southeast Asia operations of a large international bank.

• Designed a sanctions and AML compliance program for a multinational telecommunication services provider operating in 16 countries across Asia, the Middle East and Africa.

• Conducting multijurisdictional sanctions-, AML/CFT- and FCPA-compliance program assessment for a large financial services holding company and portfolio banks across the Caucasus and Middle East.

• Conducted large-scale investigations for several international banks in relation to potential breaches of AML and compliance regulations. The investigations were usually conducted in each bank’s jurisdiction and have included a number of banks in the Middle East, Europe and the UK. Following each investigation, we partnered with the banks to remediate their AML/CFT and sanctions compliance programs.

• Conducted anticorruption-, AML- and sanctions-compliance reviews, risk assessments and due diligence inquiries for numerous Fortune 500 companies.

• Advised a publicly traded company on its anti-money laundering compliance program related to its precious metals business.

Multinational conglomerates, global financial services companies and emergent startups are increasingly leveraging blockchain and distributed ledger technology for their customers. This includes creating and utilizing cryptocurrencies and other digital assets. Staying ahead of market trends in this sector takes creative counsel who are prepared for what’s next. We frequently advise our clients on best practices in the blockchain and cryptocurrency space and provide them with innovative solutions to help manage compliance risks as they shape their products and services in line with market demand. In this fast-moving and rapidly evolving regulatory environment, we separate truth from fiction and provide practical advice to those navigating the complex risks and rewards of blockchain, cryptocurrency and other distributed ledger businesses.

Our team offers a unique understanding of the current state of the blockchain and cryptocurrency markets and is adept at predicting where regulators and enforcement agencies will focus as the industry evolves. With former members of government agencies such as the US Department of Justice (DOJ), the Commodity Futures Trading Commission (CFTC), the Office of the Comptroller of the Currency (OCC), the Consumer Financial Protection Bureau (CFPB), the Office of Foreign Assets Control (OFAC), and the Financial Crimes Enforcement Network (FinCEN), as well as members of our Public Policy team who served in Congress on the Senate Committee on Finance, Senate Banking Committee, and House Financial Services Committee, we have unique insight into where cryptocurrency risk and opportunity intersect. This allows us to assist clients in navigating the complex regulatory issues that impact blockchain and cryptocurrency products and services, including compliance with securities and commodities laws and regulations, as well as US and international anti-money laundering (AML) and countering the financing of terrorism (CFT) requirements. We have deep expertise advising clients on the unique challenges that blockchain and cryptocurrency present for complying with the US Bank Secrecy Act (BSA) and the BSA’s implementing regulations, along with global sanctions requirements.

Why Choose Us?

Our fully integrated team helps clients understand and negotiate the legal, business and political issues impacting the blockchain and cryptocurrency industry, including:

• Advising financial services providers on how to assess and mitigate compliance risk regarding AML, sanctions, securities and other digital asset enforcement priorities

• Defending cryptocurrency companies, exchanges, and individuals in government enforcement actions and civil litigation proceedings

• Guiding companies through the regulatory framework analysis for cryptocurrencies, non-fungible tokens (NFTs) and other digital assets

• Assisting with implementation of economic sanctions screening and reporting

• Guidance on MSB registration with FinCEN and BitLicense application with New York State Department of Financial Services

• Preparing anti-money laundering (AML) and sanctions compliance programs, including development of financial crime compliance manuals, policies and procedures

• Advocacy at the US state and federal levels, as well as access to policy influencers globally

Our comprehensive legal expertise, insight into US and foreign government priorities and global presence allow us to quickly and proactively identify risks associated with the blockchain and cryptocurrency industry and to efficiently and effectively address them in the US and around the world.

Representative Experience

• Startup cryptocurrency exchange – Designed an anti-money laundering/combatting the financing of terrorism (AML/CFT) and US economic sanctions compliance program.

• Cryptocurrency exchange – Assisting in its New York State Department of Financial Services (DFS) BitLicense application and conducting AML/CFT and US economic sanctions gap analysis of the exchanger's AML/CFT and sanctions compliance program.

• US-based cryptocurrency exchange – Assisted with the development of a sanctions compliance program, including the drafting of policies and procedures and assisting with the implementation of a new sanctions screening system.

• CEO of a cryptocurrency exchange – Advised on an AML investigation led by the US Department of Justice (DOJ) and the Internal Revenue Service (IRS).

• Cryptocurrency exchange – Advised an Asia-based cryptocurrency exchange platform on the acquisition of money transfer licenses and its DFS BitLicense application.

• Online crypto casino – Conducting an AML and US economic sanctions gap analysis of an online crypto casino and representing the casino in investigations by US and foreign authorities. Advising on designing, drafting and implementing new AML and sanctions policies and procedures as well as compliance with international regulatory and licensing regimes.

• Blockchain association – Advised in relation to the US Securities and Exchange Commission’s (SEC) enforcement action to block the Kik and Gram distributions.

• Investor clients – Advising on significant fraudulent Bitcoin transactions arising out of initial coin offerings (ICOs).

Our Cannabis, Hemp & CBD services team provides legal advice on US federal and state legal issues to cultivators, processors, manufacturers, laboratories, researchers, retailers and suppliers in the cannabis, hemp and CBD industry.

Our team focuses on the rapidly evolving US laws governing cannabis, cannabidiol (CBD) and the hemp industry. We can represent your interests in US government enforcement, litigation, regulatory and public policy matters related to US state and federal laws governing the industry, and advise on the range of legal issues that cannabis, hemp and CBD businesses and entrepreneurs face every day.

Our Capabilities

Compliance, Government Investigations & White Collar

We are familiar with the stringent and often-changing US federal and state regulations facing the cannabis, hemp and CBD sectors. Our compliance expertise ranges from new product inception to international distribution. With our team of experienced professionals, including several who have worked for the US Department of Justice, we are ideally situated to counsel clients on compliance issues, conduct due diligence and compliance audits, and represent clients in administrative proceedings, civil and criminal investigations, and negotiations with regulators.

Public Policy

We are at the forefront of the federal and state policy discussions shaping the future of this industry. Under the leadership of former US House Speaker John Boehner, we have formed the National Cannabis Roundtable, the leading voice for advocating common-sense changes to current law. Our work focuses on tax equality, financial services reform and the rights of states and territories to regulate and manage cannabis policy.

As federal and state policies in this area take shape, our preeminent Public Policy Practice can make sure your voice is heard, at the right time and by the right people. We can also help you assess how government policies could affect your business interests. Through our involvement with the Roundtable, our team is leveraging strong Washington DC relationships and experience with Congress, the White House and relevant federal agencies to help companies anticipate potential changes to current law and take advantage of future developments.

Litigation

We combine litigation skills and industry focus to resolve complex legal matters in the US cannabis, hemp and CBD industry. Our litigators advocate for clients in courts and arbitrations across the nation and have helped to develop key legal precedents guiding businesses today. We counsel and defend clients facing pending and threatened litigation and US governmental investigations stemming from regulatory reform. We also represent clients in US state and federal courts in jury and bench trials, administrative procedures and hearings, and the appellate process. These cases include complex, bet-the-company litigation.

Food and Drug Regulations

Our regulatory teams are well placed to guide clients through the myriad laws governing the cannabis, hemp and CBD industry, including advising on issues such as product approvals and safety regulations. We help clients achieve key business objectives related to the full array of products regulated by the US Food and Drug Administration (FDA), as well as related health and safety regulatory agencies and complex state, national and global regulatory regimes.

Tax Strategy & Benefits

Tax strategy is a key legal concern in the cannabis, hemp and CBD industry. Our Tax Strategy & Benefits Practice focuses on domestic and international tax structuring and advisory work, enabling clients from all sectors to implement their decisions in the most tax-effective manner.

Labor & Employment

We assist on matters ranging from employment litigation and risk management to discrimination and harassment, immigration, executive agreements and wellness programs. We also advise on the sponsorship and employment of foreign nationals throughout the world.

Insurance

Our long history of counselling insurance and re-insurance companies on corporate, regulatory and operational issues gives us a broad understanding of the risks and issues surrounding potential or future health insurance coverage for medical cannabis in the US. We also understand the complexities cannabis, hemp and CBD businesses face when they seek insurance coverage for their business or employees.

Our US Experience

• Forming, under the leadership of former US House Speaker John Boehner, the National Cannabis Roundtable, the leading voice for advocating common-sense changes to current US law. Our work focuses on tax equality, financial services reform and the rights of states and territories to regulate and manage cannabis policy.

• Leveraging strong Washington DC relationships and experience with Congress, the White House and relevant federal agencies to help companies anticipate potential changes to current US law and take advantage of future developments.

• Serving as regulators and counsel to regulators during the development and implementation of key state cannabis programs.

• Providing regulatory advice on cannabis, hemp and CBD to multiple publically traded companies.

• Counselling clients on establishing and improving compliance programs and proactively addressing and mitigating related issues.

• Representing businesses facing federal enforcement actions.

• Providing strategic advice on obtaining market approval, determining regulatory strategies, navigating regulations and the agencies that create and enforce them, and assessing regulatory and business risks associated with a particular strategy.

• Counselling clients on advertising and promotion of legal and regulatory issues.

• Advising on product marketing, including potential enforcement actions by the US Food and Drug Administration, consumer class actions for false advertising or unfair competition, and federal Lanham Act claims.

• Representing a US state Department of Commerce in lawsuits related to the state’s Medical Marijuana Control Program.

• Advising in cases involving “hot hemp” and testing issues.

• Representing a medical cannabis company in response to criminal inquiry and civil RICO and related litigation.

• Representing real estate development company in investment dispute concerning state-of-the-art cannabis cultivation and manufacturing project.

• Representing investors in hemp related dispute.

• Representing CBD companies in contractual claims.

• Representing cannabis companies protect and monetize their intellectual property rights, including successfully obtaining trademark registrations at both state and federal levels.

• Recommending the most appropriate tax advice to our clients as they implement their investment strategies.

• Representing clients’ interests and understanding the tax dynamics of this evolving area.

• Reviewing and advising on US workplace drug policies as they relate to employee medical marijuana use, as well as whether US employers can consider an applicant’s status as a medical marijuana user in hiring decisions.

• Conducting US multistate research on the legality of medical marijuana and the restrictions on employers that are subject to federal drug testing requirements.

• Drafting drug testing policies for US employers.

• Advising one of the fastest growing US health and wellness cannabis companies on securing coverage for medical cannabis under private health insurance plans and self-funded plans, as well as Medicaid and Medicare.

• Advising an international reinsurer regarding state and federal cannabis laws.

Disclaimer

The US Agriculture Improvement Act of 2018 (2018 Farm Act) amended the Controlled Substances Act to declassify hemp as a Schedule I controlled substance, legalizing its growth, and shifting its supervision from the US Drug Enforcement Administration to the US Department of Agriculture. The 2018 Farm Act defines “hemp” as any part or derivative of the Cannabis sativa L. plant containing less than 0.3 percent THC (delta-9-tetrahydrocannabinol) by weight. This definition includes hemp plants that are processed to produce concentrated crystalline powders or liquid extracts known as Cannabidiol or CBD.

In contrast, cannabis is still classified as a Schedule I controlled substance by the US Drug Enforcement Agency, and, as such, it remains a federal crime in the US to grow, sell, possess, distribute and/or use cannabis, regardless of any state law that may decriminalize such activity under certain circumstances. Accordingly, there remains a conflict between federal laws that criminalize cannabis and the laws of states that have legalized cannabis. Even though federal enforcement policy may at times defer to state laws that have legalized cannabis, please be aware that compliance with state law in no way assures compliance with federal law, and there is a risk that conflicting federal laws will be enforced. Any content contained on this website is not intended to provide legal advice. No legal advice we give is intended to assist with the violation of any US state or federal law.

Companies that are unfamiliar with Inspector General investigations and audits can find out the hard way that Inspectors General are among the most powerful officials in the US government. Housed inside nearly every federal agency as an internal watchdog, Inspectors General work to weed out waste, fraud, abuse, and mismanagement in the programs and operations of the agencies they oversee.

Companies that receive money from an agency pursuant to a contract, grant, or cooperative agreement thereby subject themselves to the authority of that agency’s Inspector General. To ensure that recipients are entitled to receive agency money and that the money disbursed is spent in accordance with applicable laws, regulations, and terms, Inspectors General have teams of auditors and investigators. When an audit or investigation results in a factual finding that a crime (typically, some kind of fraud) has (or may have) been committed, Inspectors General are statutorily required to refer the matter to the Department of Justice (DOJ) for a determination of whether criminal prosecution or civil litigation is warranted.

Inspector General inquiries can attract the attention of Congress and the press. In cases where the allegations are especially serious and/or the amount of money at issue is large, it is not uncommon for there to be congressional hearings, media stories, and DOJ involvement all at once – the proverbial “perfect storm” that, depending on the particulars, can significantly tarnish a company’s reputation and even lower its market value.

Inspectors General can also refer their findings to agency components that have the power to suspend or debar contractors and grantees. If a company derives a significant share of its revenue from government business, suspension or debarment can be its death knell.

Given the potential stakes, Inspector General inquiries, however innocuous they may seem at first, are not to be taken lightly. When an Inspector General’s office comes knocking, it pays to have counsel with the expertise, experience, and relationships needed to maximize the chances of the most favorable possible outcome.

Our Government Investigations & White Collar Practice Group, which includes a former Inspector General and several former federal prosecutors, has decades of experience successfully representing clients being investigated or audited by Inspectors General. Examples of that experience can be found in the Experience section below, and our lawyers have authored various publications on this topic, which can be found on our website and our Global Investigations & Compliance Review blog.

Our Experience

• Represented a government contractor accused by the Navy’s Inspector General and the DOJ of failing to disclose a conflict of interest that facilitated the company’s obtaining government contracts. Ultimately, no action was taken against the client.

• Representing a government contractor with respect to a voluntary self-disclosure to the DOJ, the Department of Commerce’s Bureau of Industry and Security (BIS), and the Department of the Treasury’s Office of Foreign Asset Controls (OFAC), as well as a mandatory disclosure to the contracting agency’s Inspector General, of export control violations. “No Action” letters have been received from BIS and OFAC (awaiting resolution with the other agencies).

• Represented a company in an inquiry by the Special Inspector General for Afghanistan Reconstruction concerning processes and procedures to prevent the diversion of US government funds to the Taliban. The inquiry was closed with no action taken against the company.

• Represented a closely held government contractor whose owners were accused by the Department of Defense’s Inspector General, the DOJ, certain members of Congress, and the news media of being “delinquent” on their federal income taxes and, thus, falsely certifying that they were eligible to receive federal contracts. Ultimately, there was no finding of wrongdoing.

• Represented a nonprofit organization funded in part by DOJ grants in an investigation by the department and its Inspector General as to whether the organization misused grant funds. Negotiated a favorable settlement.

• Represented a major insurance company with respect to an audit by the Department of Homeland Security’s Inspector General of various insurance companies’ participation in the “Write Your Own” program.

• Represented a supplier of critical aerospace components to the Department of Defense in an investigation by the Inspector General and a congressional committee of the company’s pricing practices.

• Represented a NASA grantee in an investigation by NASA’s Inspector General, the National Science Foundation’s (NSF) Inspector General, the NASA’s Suspension and Debarment Office, and a US Attorney’s Office of alleged misallocation of time. Ultimately, the matter was settled, with no finding of wrongdoing.

• Represented one of the owners of a small, disabled veteran-owned business that was investigated by the Small Business Administration’s Inspector General and DOJ for allegedly falsely claiming to be such a business. Ultimately, no action was taken against the company.

• Represented, as a potential third-party witness, a consultant to school districts with regard to the federal “E-Rate” program that subsidizes the cost of certain technology purchases for districts with significant numbers of economically disadvantaged children in an investigation by the Federal Communications Commission’s Inspector General as to whether those districts were obtaining subsidies to which they were not entitled. Ultimately, the consultant was not required to testify.

• Represented an NSF grant recipient being investigated by that agency’s Inspector General and a congressional committee for allegedly misusing grant funds. Ultimately, there was no finding of wrongdoing.

Our Recognitions

• Recognized in the GIR 100 by Global Investigations Review

• Recognized for Corporate Compliance & Investigations in the UAE by Chambers Global.

• Recognized for Crime, Fraud and Licensing - Fraud: Civil in London by Legal 500 UK.

• Recognized for Risk Advisory: Regulatory Investigations and Corporate Crime (advice to corporates) in London by Legal 500 UK.

• Recognized for Crime, Fraud and Licensing – Fraud: White-collar Crime (advice to individuals) in London by Legal 500 UK.

• Recognized for Crime, Fraud and Licensing: Private Prosecutions in London by Legal 500 UK.

• Recognized for Dispute Resolution: Compliance and Investigations in the UAE by Legal 500 EMEA.

The Inspector General Podcast Series

Listen to The Inspector General podcast series for updates on oversight community developments, featuring interviews with former Inspectors General and insights into investigations, audits and the vital role of Inspectors General.