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The Foreign Corrupt Practices Act and International Anti-Corruption Developments 2014


Speaker(s): Arthur D. Middlemiss, Charles E. Duross, Cheryl J. Scarboro, Claudius O. Sokenu, David W. Simon, Erich O. Grosz, F. Joseph Warin, Glenn T. Ware, Greta Lichtenbaum, Guy D. Singer, Harry A. Chernoff, James D. Bamford, James J. Benjamin, Jr., James M. Koukios, Jay G. Martin, Joel M. Cohen, Kara N. Brockmeyer, Kathryn Cameron Atkinson, Kenneth G. Yormark, Kimberly A. Parker, Lucinda A. Low, Mark F. Mendelsohn, Mary C. Spearing, Melody Wang, Paul E. Rowsey, Peter B. Clark, Philip Urofsky, Raja Chatterjee, Richard A. Sauber, Richard N. Dean, Richard S. Levick, Esq. , Richard W. Grime, Robert E L deButts, Jr., Stephanie J. Meltzer, Stephen S. Zimmermann, Tim Coleman, Timothy L. Dickinson, William F. McGovern
Recorded on: May. 1, 2014
PLI Program #: 51316

Jim is a co-founder of Water Street Partners, where he serves a global client base in industries ranging from oil and gas, mining, and chemicals to hi-tech, and industrial manufacturing. He has supported more than 200 joint venture transactions and restructurings, and worked extensively on JV governance, organizational, and commercial issues.

Prior to Water Street Partners, Jim co-led the JV and Alliance Practice at McKinsey& Company (2001-2008). While at McKinsey, Jim founded the JV CEO and Directors Roundtable, a working group of senior practitioners running or sitting on the Boards of large joint ventures.

Jim is author of Mastering Alliance Strategy, and has written more than 100 articles on joint ventures and alliances in Harvard Business ReviewCorporate DealmakerMcKinsey Quarterly, the Joint Venture Exchange, and other publications.

Prior to McKinsey, Jim worked in Asia for an affiliate of Booz-Allen-Hamilton in Asia, served as the editor of The Alliance Analyst, and headed a successful information services company focused on providing merger, acquisition, and joint venture transaction advice to large global companies.

Jim has an undergraduate degree from Tufts University, and graduate degrees from the London School of Economics and Harvard University.

 


Admission & Qualifications

District of Columbia Bar
New York State Bar

Education

Vassar College, 1972, B.A.
Fordham University School of Law, 1976, J.D., Art History

Professional Profile

A partner in the Litigation Department since 1999, Mary Spearing focuses her practice on white collar criminal defense, internal investigations and corporate compliance counseling. Mary has amassed a broad range of experience from her government experience to the boardroom. She has tried more than 35 cases to verdict. Her clients have included corporations, officers, directors and professionals in regulatory, investigative and trial matters. She has litigated for the government and the defense in numerous state and federal courts. She has been hired by audit committees or special committees of public companies across a range of industries to conduct investigations into allegations of wrongdoing.

Representative Matters

Represented the former CEO of Rite Aid in a securities fraud/obstruction of justice case brought by the U.S. Department of Justice (DOJ)

Represented Halliburton in the FCPA investigation conducted by the U.S. DOJ and Securities and Exchange Commission (SEC)

Represented Noble Corp. in an FCPA investigation conducted by the U.S. DOJ and SEC, resulting in a non-prosecution agreement by the DOJ

Represented the Audit Committee of an oil services company in a DOJ/SEC FCPA investigation, resulting in no action by the enforcement agencies

Represented a Fortune 100 entertainment company in an internal investigation regarding FCPA allegations related to their business in China

Represented a private international contractor in a DOJ prosecution for Clean Water Act violations Salt Lake City Olympic Committee Chief Financial Officer-DOJ bribery investigation Compliance officer of environmental testing lab for violation of False Statement Act  Sinclair Oil Refinery in a DOJ prosecution for environmental RCRA offenses

Represented a private equity fund regarding FCPA compliance issues related to African and South American investments

Represented a member of the Senate staff in a campaign finance investigation conducted by the U.S. Attorney’s office in the Southern District of New York

Represented an Iranian businessman under investigation by the U.S. Attorney for the District of Columbia regarding violations of the Iranian sanctions laws

Represented an aerospace manufacturer in an internal investigation regarding FCPA allegations A Canadian company under investigation for corruption related activities by the U.S. DOJ and the Canadian Crown Prosecution Service

Represented a Japanese automobile manufacturer under investigation by the DOJ for false advertising and bank fraud

Other Distinctions

Mary is a frequent speaker on white collar topics at numerous ABA, international conferences and industry programs. She has been a litigation guest lecturer at white collar seminars at Georgetown University Law School and American University’s law school.

She has been named each year one of the country’s top lawyers in The Best Lawyers in America, The Washingtonian Magazine’s Top Lawyers, Washington Post’s Superlawyers of DC and The International Who’s Who of Business Lawyers.

Prior Experience

US Department of Justice, Criminal Division (1989-1999)
 -Chief, Fraud Section, 1994-1999
 -Chief, General Litigation Section, 1991-1994
 -Deputy Chief, Child Explotation and Obscenity Section, 1989-1991

Assistant US Attorney, US Attorney’s Office, Middle District of Pennsylvania (1984-1988)

Assistant US Attorney, US Attorney’s Office, Eastern District of Pennsylvania (1981-1984)

Attorney, US Department of Energy, Office of Special Investigations (1979-1981)

Attorney, New York City Department of Investigation (1976-1979)




Arthur D. Middlemiss
Lewis Baach PLLC

Arthur Middlemiss practices in the areas of financial crimes compliance. Mr. Middlemiss has extensive experience planning, building, and running global financial crimes compliance programs, with a particular emphasis on anti-corruption and anti-money laundering. He provides strategic counsel to foreign and domestic entities seeking to mitigate regulatory, criminal and reputational risk. His expertise includes securities and other fraud-related investigations. Previously, Mr. Middlemiss directed the anti-corruption program of one of the world’s largest financial institutions, where he also held senior positions related to anti-money laundering compliance. From September 1994 to June 2007, Mr. Middlemiss served as an Assistant District Attorney in the New York County District Attorney’s Office. As Bureau Chief of Investigations Division Central, also known as DANY Overseas, Mr. Middlemiss supervised the investigation and prosecution of complex white collar criminal cases, focusing on matters involving securities fraud, international money laundering, tax evasion, and illegal money remitters. Multiple investigations produced settlements that required major domestic financial institutions to reform their compliance procedures. Among other matters, Mr. Middlemiss co-led the District Attorney’s investigation into the role of financial institutions in Enron’s collapse.


Cheryl Scarboro is a Partner in the Washington, D.C. office of Simpson Thacher & Bartlett LLP and a member of the Firm’s Government and Internal Investigations Practice. Cheryl represents corporations, financial institutions and individuals in SEC and other regulatory enforcement proceedings. She conducts internal investigations on behalf of management and boards of directors and counsels clients on Foreign Corrupt Practices Act (“FCPA”) compliance programs, SEC reporting, disclosure and corporate governance requirements.

Cheryl joined the Firm following a 19-year tenure at the Securities and Exchange Commission, most recently as the first Chief of the SEC’s FCPA Unit in the Division of Enforcement. While at the SEC, Cheryl led significant investigations involving a broad variety of subjects, including alleged violations of the FCPA, the Investment Advisers Act, issuer accounting fraud and other disclosure violations, market manipulation, broker-dealer misconduct and insider trading.

As head of the SEC’s FCPA practice, Cheryl played a role in all of the SEC’s recent major FCPA cases and acted as the SEC liaison with the Department of Justice (DOJ) and regulators around the world. In particular, Cheryl led the SEC’s investigation of Siemens, A.G., which resulted in an unprecedented $1.6 billion settlement with the SEC, DOJ and German regulators, the largest settlement to date under the FCPA. She also led investigations that resulted in actions against 15 companies and three individuals charged with making illicit payments to the Iraqi government in order to win contracts under the United Nation’s Oil-for-Food Program. In a recent FCPA investigation of a Luxembourg-based global steel pipe supplier and manufacturer, Cheryl pioneered the SEC’s first use of a deferred prosecution agreement as a means of resolving the investigation in a manner that recognized the entity’s cooperation.

Cheryl held numerous other roles while at the SEC, including serving as an Associate Director in the Division of Enforcement and as counsel to former SEC Chairman Arthur Levitt. In addition to FCPA matters, Cheryl was responsible for a number of significant financial fraud cases, including the SEC’s recent action involving Satyam Computer Services Limited, and several major insider trading cases, including the SEC’s recent action against a hedge fund manager alleged to have orchestrated a $30 million insider trading scheme.

She was named to the “Enforcement 40” by the Securities Enforcement Forum, is recognized by The Legal 500 as a leader in her field, and named a “Litigation Star” by Euromoney’s Benchmark Litigation.

She earned her J.D. from Duke University School of Law in 1989 and her B.A. from University of Alabama in Huntsville in 1986.


David W. Simon is a litigation attorney who devotes much of his practice to helping corporate clients avoid and manage crises that potentially give rise to government enforcement actions.

The Foreign Corrupt Practices Act (FCPA) is a principal focus for Mr. Simon. A frequent author and speaker on the FCPA and anti-corruption issues, he has been recognized for his extensive experience in the field. Mr. Simon counsels clients on FCPA issues that arise in their operations, assists clients in the development and implementation of anti-corruption compliance programs, advises clients on third-party anti-corruption due diligence, conducts internal investigations into FCPA and other anti-corruption issues, and defends corporate clients in government enforcement actions that arise from potential FCPA violations.

Significant Recent Representative Matters

  • Conducting an internal investigation into potential FCPA violations arising out of improper payments to consultants by a manufacturing client’s India subsidiary and providing anti-corruption compliance advice;
  • Serving as lead appellate FCPA counsel for Carlos Rodriguez in the case U.S. v. Esquinazi, Case No. 11-15331, the first federal appeals court case to address the meaning of the FCPA’s “foreign official” element;
  • Conducting an internal investigation into and coordinating the voluntary disclosure of potential FCPA violations arising out of gift and entertainment expenditures of an agricultural industry client’s China subsidiary;
  • Conducting an internal investigation into potential FCPA violations arising out of the business practices of a manufacturing client’s agent in Indonesia;
  • Participating in a global anti-corruption compliance review for a multi-national oil and gas company;
  • Representing a manufacturing client in connection with FCPA issues arising out of a former subsidiary’s business practices in China, including conducting an internal investigation, coordinating a voluntary disclosure to the SEC and DOJ, and negotiating a resolution with the enforcement authorities

Recognition

Mr. Simon has been Peer Review Rated as AV® Preeminent™, the highest performance rating by Martindale-Hubbell and was selected for inclusion in the current edition of The Best Lawyers in America® for criminal defense: white-collar law.

Affiliations

Mr. Simon currently serves as a member of the board of directors for the Federal Defender Service of Wisconsin and as a member of the City of Delafield Plan Commission.

Education

Mr. Simon graduated with honors from the University of Wisconsin – Madison (B.A., 1989), and from the University of California – Berkeley, Boalt Hall School of Law (J.D., 1994), where he was elected to the Order of the Coif and was a member of the California Law Review. He joined the firm after a judicial clerkship with the Honorable Robert W. Warren, U.S. District Court for the Eastern District of Wisconsin.

Admissions

Mr. Simon is admitted to practice in both Wisconsin and the District of Columbia.


DICK SAUBER is a litigator who represents companies and individuals in connection with Government investigations and enforcement actions of all types.  He has tried dozens of criminal and civil cases and regularly appears for clients in Congressional hearings, Government agency proceedings, and grand jury matters.  He has conducted internal investigations for companies in nearly every industry in the United States.

Since entering private practice in 1984, Dick has spent significant time representing government contractors.  He was the first defense lawyer to challenge the constitutionality of various provisions of the 1986 amendments to the False Claims Act, and the first defense lawyer to try a FCA retaliation case.  He has since handled dozens of FCA and Qui Tam cases.

Dick also represents clients in connection with FCPA matters.  He routinely conducts internal investigations and has worked on FCPA matters in China, Taiwan, Germany, Russia, the Middle East, and northern Africa.  He advises companies in acquisitions on law enforcement due diligence matters on a regular basis.

Before entering private practice, Dick was a federal prosecutor for seven years.  He was appointed by President Reagan to form and lead the first multi-agency task force to concentrate on pursuing fraud in government contracts.  He was a partner for 23 years at Fried, Frank, Harris, Shriver & Jacobson where he was the Chair of the firm’s Washington Litigation Department and a member of the firm’s Management Committee.  He is an adjunct professor at Georgetown Law School where he has taught a National Security Crimes seminar and an evidence class.  He has tried jury cases in New York, Washington, California, Texas, Nevada, Mississippi, and Oklahoma, and his appellate work includes arguing cases before the Supreme Court and nearly every one of the Circuit Courts of Appeal.

Representative matters include: 

  • Represented Northrop Grumman in multiple government civil and criminal cases since 1986
  • Represented Community Health Services in multiple government and Qui Tam matters
  • Represented a major Wall Street financial institution in a Justice Department investigation of the Credit Default Swap market 
  • Represented the Board of a major energy company to conduct an internal investigation of a fatal pipeline rupture and explosion 
  • Represented a major private equity firm under scrutiny in the “pay to play” investigation conducted by Attorney General Andrew Cuomo
  • Represented reporter Matt Cooper of Time Magazine in the Valerie Plame matter
  • Performed the due diligence for a major New York buy-out firm in connection with a multi-billion dollar acquisition in the health care industry

Professional Activities, Publications and Honors

  • Adjunct Professor, Georgetown Law School
  • General Counsel, Freedom House
  • Board of Directors, Children’s Hospital, Washington D.C.

Education: 

  • J.D., New York University School of Law, 1977
  • M.Litt., Oxford University, 1975, Rhodes Scholar, 1973 - 1975
  • B.A., magna cum laude, Yale University, 1972


Glenn T. Ware, Esq. is a Principal/Practice Group Leader at PricewaterhouseCoopers LLP (PwC) and leads the Anti-Corruption & Corporate Intelligence Practice for the U.S. firm.  He also founded PwC’s Anti-Corruption Centre of Excellence – the first of its kind private sector organization dedicated to collecting and promulgating best practices in anti-corruption for the public and private sectors. For clients, he directs a diverse group of over 50 interdisciplinary investigative, forensic, technology, and intelligence professionals that offer the full spectrum of anti-corruption services across all business sectors – both public and private. Mr. Ware is an international lawyer by training. Prior to coming to PwC, he served as the Chief Investigative Counsellor to the President of the World Bank Group where he was a chief architect and directed the anti-corruption investigative function across the entire Bank portfolio. While at the Bank, he ran the Africa Investigative Unit for five years before being promoted to Chief Counsellor. He has lived and worked extensively overseas in Africa, Eastern Europe, the Middle East, Europe and Latin America, assisting private and public sector clients navigate the complex business, ethics and legal challenges in emerging and post conflict markets. He led the establishment of PwC's office in Iraq, and established and led the PwC response team for President Bill Clinton following the devastating earthquake in Haiti to ensure money was used for its intended purposes.

Mr. Ware serves a variety of industry sectors across the globe - addressing a full range of corruption challenges. He is a “board room level advisor” to these companies in helping them address a variety of complex compliance and regulatory challenges. On top of Mr. Ware’s recognized anti-corruption expertise, he has deep experience in international and national security matters following 26 years of government experience as a senior Navy Officer with the Office of Judge Advocate General. He holds an active top secret security clearance and sits on the leadership steering committee of PwC’s Threat Management Groups and has worked for various U.S. and foreign government agencies. Mr. Ware has been retained by former and current heads of State, a Nobel Prize winner and current and former cabinet level officials in the United States and abroad.  

Mr. Ware has lectured at professional and academic forums, including the American Bar Association, International Bar Association, Harvard Law School, Georgetown Law School, the Joint Vienna Institute, U.S. State Department, the Pentagon, the EU, OECD, The World Bank Group, Inter-American Development Bank, Naval War College, National War College, Air War College, Fletcher School of Law and Diplomacy, J.F. Kennedy School of Government, and numerous institutions and professional forums around the world. 

Mr. Ware holds an LLM from Harvard Law School. He is extensively published and quoted as an authority in the media in the areas of fraud and anti-corruption, corporate intelligence, national security, and international governance. He is a member of the ABA National Security Law and International Law sections. He sits on the World Economic Forum's Task Force for Anti-Corruption (PACI), Transparency International USA's Corporate Counsel Forum, and was recently selected by the OECD as a participant for their site inspection of the United States compliance with the OECD Convention against Corruption. In addition to Haiti, Mr. Ware spends a considerable amount of time in Iraq advising the Kurdistan Regional Government on governance issues.


Guy Singer is a partner in the New York office and a member of the White Collar and Criminal Investigations group. Guy also maintains an office in the Washington, D.C., office. His practice focuses on litigation with an emphasis on white collar and corporate compliance matters. He has provided significant representation with respect to internal investigations involving alleged violations of the Foreign Corrupt Practices Act (FCPA), criminal antitrust investigations and prosecutions, and Department of Justice investigations involving the International Traffic in Arms Regulations (ITAR).

Guy is a former trial attorney in the Department of Justice's Criminal Division, Fraud Section. While at the Department of Justice, Guy investigated and prosecuted white collar crime and public corruption throughout the United States, from grand jury through trials, including allegations of bribery, bank fraud, money laundering, securities fraud, obstruction of justice, mail/wire fraud, honest-services fraud and violations of the FCPA and Internal Revenue Code. During his tenure with the Department of Justice, he received numerous commendations and recognition from federal and state law enforcement agencies for his work. He previously focused on public corruption and organized crime matters while an Assistant State Attorney at the Miami-Dade County State Attorney's Office, as well as a Special Assistant US Attorney in the Southern District of Florida.

Due to his extensive experience handling high-profile matters of public corruption and white-collar crime, Guy is often called on by the national media for commentary. Among others, he has appeared on CNN and been quoted in The Washington Post, the L.A. Times and The Philadelphia Inquirer.

Related Practice Areas

  • White Collar & Corporate Investigations
  • International Arbitration & Dispute Resolution

Education

  • J.D., New England School of Law, 1992
  • B.A., Psychology, University of Hartford, 1987

Honors

  • "Assistant Attorney General's Award for Ensuring Integrity of Government," investigation and prosecution of Jack Abramoff and related parties, United States Department of Justice
  • "Meritorious Award," superior performance of duties, United States Department of Justice


James J. Benjamin Jr., a leader of Akin Gump’s securities enforcement and litigation practice group, represents clients in a wide variety of government and regulatory investigations and litigation. He also handles appellate and complex commercial litigation.

Mr. Benjamin has extensive experience with matters arising under the federal securities and commodities laws including allegations of foreign corrupt practices, insider trading, improper accounting and disclosure, market manipulation, and other trading violations. He represents both institutional and individual clients and has served as lead counsel in numerous internal investigations. Many of his clients are based outside the United States. Mr. Benjamin has conducted numerous jury trials and has briefed and argued many cases before federal and state appellate courts.  He has been recognized for a number of years as a leading lawyer by Chambers USA: America’s Leading Lawyers for Business in the areas of white-collar crime and government investigations and in other publications including The Who’s Who Legal 100 and Best Lawyers in America.

Before joining Akin Gump in early 2001, Mr. Benjamin served for more than five years as a federal prosecutor in the U.S. Attorney’s Office for the Southern District of New York. During his tenure there, he served as deputy chief appellate attorney and as a member of the Securities and Commodities Fraud Task Force. As an assistant U.S. attorney, he received an award for superior performance from Attorney General Janet Reno in 2000. Before joining the U.S. Attorney’s Office, Mr. Benjamin served as a law clerk at the U.S. Supreme Court for Justices Lewis F. Powell Jr. and John Paul Stevens. Before that, he worked for several years as an associate at a major Washington, D.C.-based law firm and served as a law clerk for the Honorable J. Frederick Motz, a federal district judge in the District of Maryland.

Mr. Benjamin received his A.B. magna cum laude in 1987 from Dartmouth College, where he was a member of Phi Beta Kappa and was awarded the Colby Government Prize. He earned his J.D. with honors in 1990 from the University of Virginia School of Law, where he was the research and projects editor of the Virginia Law Review and a member of the Order of the Coif.

Mr. Benjamin is a member and former chair of the New York City Bar Association’s Task Force on National Security and the Rule of Law and is a member and committee chair of the New York Council of Defense Lawyers. He is also a member of the New York State Association of Criminal Defense Lawyers and the Federal Bar Council. He has spoken extensively on developments in white-collar practice, especially regarding SEC enforcement and the FCPA.


James M. Koukios is Senior Deputy Chief of the Fraud Section in the Criminal Division of the U.S. Department of Justice.  Mr. Koukios first joined the Fraud Section as a Trial Attorney in the Fraud Section’s Foreign Corrupt Practices Act (FCPA) Unit in 2009.  In 2012, he was promoted to Assistant Chief of the FCPA Unit, where, for nearly two years, he led a team of dedicated trial attorneys who prosecute and investigate violations of the FCPA and related statutes by corporations and individuals.  From 2010-2011, Mr. Koukios served as special counsel to the FBI Director, advising the Director and other FBI executives on policy issues related to criminal investigations.  Before joining the Fraud Section, Mr. Koukios was an Assistant U.S. Attorney in Miami for four-and-a-half years where he prosecuted and tried cases involving arms trafficking, immigration offenses, narcotics offenses, violent crimes, and economic crimes.  Prior to joining the U.S. Attorney’s Office in Miami, Mr. Koukios was a litigation associate for three years at a major U.S. law firm and served as a law clerk for then-U.S. District Court Judge Edith Brown Clement in the Eastern District of Louisiana. Mr. Koukios is an adjunct professor of trial practice at the Georgetown University Law Center. Mr. Koukios received his B.A. with highest distinction from the University of Michigan and his J.D. cum laude from Harvard Law School.


JAY G. MARTIN is the Vice President, Chief Compliance Officer and the Senior Deputy General Counsel for Baker Hughes Incorporated (“BHI”). Prior to joining BHI, Mr. Martin was a Shareholder at Winstead Sechrest & Minick P.C., a Partner at Phelps Dunbar and Andrews & Kurth, and the Assistant General Counsel of Mobil Oil Corporation’s Worldwide Exploration and Production Division in Fairfax, Virginia.  Mr. Martin has also served as General Counsel of Mobil Natural Gas, Inc. in Houston, Texas.  Mr. Martin holds JD, MPA and BBA degrees from Southern Methodist University in Dallas, Texas.

While in private practice, Mr. Martin was engaged in a wide variety of domestic and international energy transactions, and regulatory matters for natural gas exploration and producing companies, oil field service companies, marketers, pipelines and refiners. Mr. Martin’s practice involved such diverse matters as participating in generic federal and state restructuring proceedings in the natural gas and electric industries, drafting virtually every type of domestic and international oil and gas agreement, working on mergers and acquisitions, asset acquisitions and divestitures, handling a significant number of energy lending transactions including but not limited to mezzanine and conventional production based financings and work-out situations, and advising clients on a wide variety of natural gas marketing and processing matters.  Mr. Martin also regularly handled problems for clients arising under the Foreign Corrupt Practices Act, the U.S. Economic Sanctions Laws and Arab Boycott Regulation. In addition, Mr. Martin developed broad experience in crisis management, designed corporate compliance programs for clients, and conducted many types of internal investigations for clients.


Joel M. Cohen, a trial lawyer and former federal prosecutor, has led or participated in 24 civil and criminal trials in federal and state courts. He is equally comfortable leading confidential investigations, managing crises, or advocating in court proceedings. His experience includes all aspects of FCPA/anticorruption issues, insider trading, securities and financial institution litigation, class actions, sanctions, money laundering and asset recovery, with a particular focus on international disputes and discovery. While in government service, he was the prosecutor of the so-called “Wolf of Wall Street,” was the first U.S. Legal Advisor to the French Ministry to Justice and was an advisor to the OECD in connection with its anti-corruption convention. Mr. Cohen has achieved significant victories pretrial and at trial in many high-profile matters, including:

  • Winning a jury trial in the closely-watched Securities and Exchange Commission v. Obus insider trading matter on behalf of Wynnefield Capital and its chief portfolio manager after a twelve-year battle with the SEC.
  • Obtaining summary judgment for Citi in a class action seeking more than $13 billion in damages for its alleged role in the Parmalat collapse.
  • Winning a jury trial for AllianceBernstein in which the Florida state pension fund attempted to recover $3.2 billion in losses sustained in Enron and other stocks, and successfully defended the same client in other significant Enron-related litigations, one of which resulted in an award of attorney’s fees and costs for his client.

His recent engagements include:

  • Represented senior management and employees of a European bank in a large U.S. economic sanctions investigation.
  • Acted as independent examiner for several Swiss banks in connection with the DOJ’s “Tax Non-Prosecution Program.”
  • SEC v. Obus: Achieved trial victory and exoneration for Nelson Obus and Wynnefield Capital, a prominent hedge fund, in one of the longest fought insider trading cases in history.
  • Abu Dabi Commercial Bank v. Moody’s et al: Successfully defended Moody’s in two matters concerning their ratings of structured investments.
  • North Carolina Utilities Commission/Duke Energy: Represented Duke Energy legacy board of director members in connection with outstanding derivative and class action litigations and a resolved regulatory matter arising from the Duke-Progress corporate merger.
  • Athale v. Sinotech: Successfully defended UBS, Citi and Lazard in a class action (and related SEC inquiry) alleging violation of federal securities laws in the underwriting of the $165 million IPO for SinoTech, a Chinese issuer delisted from NASDAQ following allegations that SinoTech was a shell operation.
  • SEC v. Allianz SE: Obtained a rare declination to prosecute from the Department of Justice and highly favorable SEC settlement on a cease-and-desist bases, in which both agencies were convinced not to proceed on an aggressive “private equity liability” theory relating to FCPA-related issues.
  • Expro: Represented a major oil and gas service company, involving reviews in more than a dozen countries, on five continents, resulting in no charges brought anywhere globally.
  • Represented several private equity and investment management funds in connection with SEC and Department of Justice FCPA-related investigations.
  • United States v. Alliance One: Acted as monitor counsel for AllianceOne in connection with a three year DOJ and SEC FCPA-related monitorship.
  • Represented several Fortune 100 companies in global regulatory investigations relating to corporate fraud, corruption/FCPA issues, sanctions issues, and insider trading concerns.
  • Represented a major accounting firm, convincing the SEC not to bring charges for alleged violations of the auditor independence rules.
  • Represented a Wall Street general counsel, convincing the SEC to decline to bring insider trading charges.
  • SEC v. Stoker: Represented the former head of CDO trading at a top global bank in connection with several related criminal and regulatory and civil litigations in which no charges were brought against client.
  • Represented multiple financial institutions in designing crisis management and global anticorruption programs.
  • Represented many audit and special committees of public companies and private company boards of directors in connection with allegations of wrongdoing.
  • Represented many tobacco and firearms producers in product liability actions.

Mr. Cohen is committed to pro bono work. He serves on the board of or acts as outside counsel to several prominent nonprofit entities, including New York Lawyers for the Public Interest, Lawyers Without Borders, and Jericho Project. He successfully led a team of Gibson Dunn attorneys in representing all plaintiffs in a high-profile immigration civil rights case (Barrera v. Boughton) in Connecticut federal court, which resulted in the largest settlement in history for such claims, for which the Firm has been awarded the National Legal Aid & Defender Association’s 2010 Beacon of Justice Award, and The New York Times noted the accomplishment in an editorial, and his team received the National Law Journal’s Hot Pro Bono 2012 designation.

Mr. Cohen previously was Head of U.S. Litigation at Clifford Chance, where he practiced from 2004 to 2009. From 1999 to 2004, he practiced with Greenberg Traurig. From 1992 to 1999, he served as Assistant United States Attorney in the Eastern District of New York, supervising the Business/Securities Fraud Unit, where he received numerous awards from the Department of Justice and law enforcement agencies. Mr. Cohen was the prosecutor of Jordan Belfort and Stratton Oakmont, which is the focus of “The Wolf of Wall Street” film by Martin Scorsese. He was an adviser to OECD in connection with the effort to prohibit corruption in international transactions and was the first Department of Justice legal liaison advisor to the French Ministry of Justice. Mr. Cohen has published several articles on securities, international and white collar litigation issues and has been a presenter and chair at many professional conferences. He is also a frequent commentator in print and television media. Mr. Cohen has been named a leading white collar criminal defense attorney by The Best Lawyers in America©, a “Litigation Star” by Benchmark Litigation, a “Super Lawyer” in Criminal Litigation, and his work is noted by Legal 500 in the areas of white collar criminal defense and securities litigation, and in Chambers in the white collar area. In addition, The Am Law Litigation Daily named Mr. Cohen as one of its Litigators of the Week after winning a jury defense verdict in an insider trading case on behalf of Nelson Obus, general partner of Wynnefield Capital.

Mr. Cohen received his bachelor’s degree from Middlebury College, his master’s degree in History from Duke University and his Juris Doctor from Duke University Law School, where he was a moot court champion. He is a member of the bars of New York and Massachusetts.

Recent Speaking Engagements

  • False Claims Act Conference, New York, May 2014
  • Keynote Speaker, Offshore Alert Conference, Miami, May 2014
  • Hedge Fund Compliance Master Class, New York, February 2014
  • “The Wolf of Wall Street: Behind the Scenes of Stratton Oakmont,” Heyman Center on Corporate Governance, January 2014
  • Financial Institutions in the Crosshairs: The False Claims Act and FIRREA, October 2013
  • Private Equity Operations & Compliance Forum, September 2013
  • SEC & DOJ Hot Topics 2013 Breakfast Briefing, New York, December 2012
  • PLI FCPA 2012 Conference, New York, May 2012
  • ACI National Conference on FCPA, New York, April 2012
  • PLI FCPA 2011 Conference, New York, May 2011
  • ACI FCPA-Health Sciences Conference, New York, May 2010
  • ACI Annual FCPA Conference, Washington, D.C., November 2008
  • Legal IQ Annual Securities Litigation Conference, New York, May 2008
  • “Ethics and Experts,” 2007 Antitrust Law Section Symposium, New York State Bar Association

Recent Publications

  • Op-ed, “The Real Belfort Story Missing From ‘Wolf’ Movie,” The New York Times, January 7, 2014.
  • “Nepotism: Friendly Relations? When Nepotism May Violate the FCPA,” The FCPA Report, October 17, 2012
  • “Foreign Corrupt Practices Act,” The US Private Real Estate Fund Compliance Guide, Private Equity International, June 1, 2012
  • “Does That Settle It? Well, Maybe Not,” National Law Journal, April 9, 2012
  • “Private Equity Investment and the FCPA,” Review of Securities and Commodities Regulations, Fall 2011
  • “Insider Trading: It’s Not for Suits,” Law Journal Newsletters, December 2010
  • “Six Ways a Board Can Manage FCPA Risk,” Corporate Board Member Magazine, October 1, 2010
  • “UK Serious Fraud Office Discusses Details of UK Bribery Act with Gibson Dunn,” September 7, 2010
  • “Erosion of the Fiduciary Duty Requirement in Insider Trading Actions,” Securities Litigation Journal, American Bar Association, Spring 2010
  • “Narrow, Don’t Abolish: The Facilitating Payments Exception to the FCPA,” The New York Law Journal, July 8, 2010
  • “Mutual Fund Litigation Triggered By the Credit Crisis,” The Review of Securities & Commodities Regulation,” June 3, 2009
  • “Under the FCPA, Who Is a Foreign Official Anyway?”, The Business Lawyer, 2008
  • “Due Diligence Under the Foreign Corrupt Practices Act: Defining a Foreign Official,” Clifford Chance US Regulatory & White Collar Update, 2008
  • “Anti-Money Laundering Laws and Regulations for Broker-Dealers: Spotlight on Foreign Broker-Dealers,” Clifford Chance Client Memo, 2008
  • “The U.S. Foreign Corrupt Practices Act and its Application to Foreign Companies that Do Not Issues Securities in the U.S.,” Clifford Chance Client Memo, 2008
  • “Five Things to Know About the FCPA,” Corporate Compliance Zeitschrift, January 2008
  • “SEC on Corporate Penalties: Two Steps Forward, One Step Backward,” New York Law Journal, February 2006
  • “Toward True Deterrence of Government Misconduct,” New York Law Journal, October 2004
  • “Regulation FD,” New York Law Journal, October 2002

Recent Media

  • “SEC Loses Insider-Trading Case,” The Wall Street Journal, May 30, 2014
  • “After Fighting Insider Trading Charges for 10 Years, a Fund Manager Is Cleared,” The New York Times, May 30, 2014
  • “12 Years Later, a Fund Manager Gets to Give His Side,” The New York Times, May 27, 2014
  • “Nelson Obus’s Lawyer Says His Client Is Honest or the ‘Lamest Insider Trader in History’,” The Wall Street Journal, May 19, 2014
  • “NY fund manager made insider trading ‘jackpot,’ SEC tells jurors,” Reuters, May 19, 2014
  • “The Wolf Hound Of Wall Street: Joel M. Cohen on Jordan Belfort, White Collar Work, And Corruption.” Forbes, May 6, 2014
  • “Inside Money: The real sheep of Wall Street?,” The New Zealand Herald, January 14, 2014
  • “Prosecutors Give Poor Reviews to Restitution From 'Wolf of Wall Street',” WSJ.com, January 12, 2014
  • “Jordan Belfort: The real wolf of Wall Street and the men who brought him down,” The Independent, January 12, 2014
  • “Boulton and Co.”, Sky News, January 10, 2014
  • “The Wolf of Wall Street: Why we like a villain,” BBC News, January 9, 2014
  • “'Wolf of Wall Street' prosecutor says film glorifies Belfort,” Fox Business, January 9, 2014
  • “Blockbuster Backlash,” CBS Morning News, January 8, 2014
  • “The Wolf of Wall Street Glorifies Crook’s Misdeeds Critics Say,” CBS Insider News, January 8, 2014
  • Op-ed, “The Real Belfort Story Missing From ‘Wolf’ Movie,” The New York Times, January 7, 2014
  • “‘Wolf of Wall Street’ Prosecutor Lambasts the Movie - Joel Cohen on Jordan Belfort,” WSJ.com, January 2, 2014
  • “Gibson Dunn teams with Lawyers Without Borders on Kenyan anticorruption effort,” National Law Journal, August 21, 2012
  • “Pro Bono Hot List,” National Law Journal, January 2, 2012
  • “The Curious Case of Nelson Obus,” The New York Times, Sunday Business Section Feature Article, June 5, 2011
  • “Attorneys from Gibson Dunn Tally 9000 Hours in Day Laborer’s Cause,” National Law Journal, March 24, 2011
  • “Danbury 11,” Editorial, The New York Times, March 14, 2011

PRACTICES

  • Real Estate Investment Trust (REIT)
  • Securities Enforcement
  • Securities Litigation
  • White Collar Defense and Investigations

EDUCATION

  • Duke University
    1988 Juris Doctor
    1988 Master of Arts
  • Middlebury College
    1984 Bachelor of Arts

ADMISSIONS

  • Massachusetts Bar
  • New York Bar

RECENT PUBLICATIONS

Webcast - Financial Institutions in the Crosshairs: The False Claims Act and FIRREA

Decoding FCPA Enforcement: The U.S. Government Issues Comprehensive Guidance on the Foreign Corrupt Practices Act

Nepotism: Friendly Relations? When Nepotism May Violate the FCPA

Foreign Corrupt Practices Act

Does That Settle It? Well, Maybe Not


Kara Novaco Brockmeyer
Chief, Foreign Corrupt Practices Act Unit
Division of Enforcement
U.S. Securities and Exchange Commission

Kara Novaco Brockmeyer is the Chief of the Foreign Corrupt Practices Act Unit of the SEC’s Enforcement Division.  In that role, she oversees nationwide investigations into violations of the anti-bribery and accounting provisions of the federal securities laws.  She was one of the principal authors of the joint SEC-DOJ Resource Guide to the U.S. Foreign Corrupt Practices Act.   Prior to becoming Chief of the FCPA Unit, Ms. Brockmeyer served as an assistant director in the division, where she supervised a broad range of SEC investigations, including investigations into FCPA violations, accounting fraud, market manipulation, public offerings, misconduct by regulated entities, and insider trading.  She is the recipient of numerous awards, including the SEC’s Capital Markets Award and the Irving M. Pollack Award.

Before joining the SEC, Ms. Brockmeyer was in private practice with a large law firm in Chicago, primarily focused on securities and complex commercial litigation.  She received her B.A. cum laude from Williams College and her J.D. magna cum laude from the University of Michigan Law School, where she was Note Editor of the Michigan Law Review.


Kenneth G. Yormark, CPA, CFE, CFF, CAMS

Kenneth Yormark is a Managing Director in Grant Thornton’s Forensic and Valuation Services Practice. Mr. Yormark focuses his practice on accounting issues, forensic accounting, financial investigations, securities litigation, and anti-corruption risk assessments. He works with management at major corporations, noted law firms, and government agencies primarily in regard to internal investigations, accounting related litigation matters, and anti-corruption/Foreign Corrupt Practices Act (FCPA) issues in both reactive and proactive environments. He has testified in deposition and at trial in Federal and Bankruptcy courts.

Mr. Yormark is an Adjunct Professor at Georgetown University Law Center where he teaches “Accounting for Lawyers”. He is also a faculty member of the Practicing Law Institute and an adjunct faculty member of the Association of Certified Fraud Examiners.

Experience

Mr. Yormark has more than 30 years of experience in the areas of forensic and investigative services, having managed and conducted numerous complex, often high-profile securities fraud, anti-corruption/FCPA and Ponzi scheme investigations involving public and private companies in all industries around the globe. Prior to joining Grant Thornton, Mr. Yormark was a Managing Director and leader of a major consulting firm’s New York Forensic Accounting Practice.  As Managing Director of another firm’s Business Risk Practice, he served as national leader of financial investigations and anti-fraud initiatives. He was Director of Forensic and Investigative services at a Big 4 firm and a Director in the Forensic Accounting Practice of a global corporate investigations firm.

Professional memberships

• American Institute of Certified Public Accountants
• Association of Certified Fraud Examiners
• New York State Society of Certified Public Accountants
• Member, ABA Section of Business Law
• Partner to the ABA Litigation Section – Business
Torts and Unfair Competition Committee
• Past partner to the ABA Litigation Section –
Criminal Investigations and Access to Justice
and Children’s Rights Committees
• New York Lawyers for Public Interest,
Committee Member
• Make-A-Wish Foundation
• Circle of Friends

Education

Bachelor of Science degree, from Queens College and Graduate Studies from New York University.


Peter Clark is senior counsel in the White Collar Defense and Investigation and Complex Litigation Practices, resident in the Washington D.C. office.

Prior to joining Cadwalader, Peter served as Deputy Chief of the Fraud Section of the Criminal Division of the Department of Justice, where he had previously held the position of Senior Litigation Counsel. Before his tenure at the DOJ, he was Special Counsel in the Division of Enforcement of the Securities and Exchange Commission, which he joined at the request of William Casey, then Chairman of the SEC.

Prior to his government service, Peter was with New York's Hall, Casey, Dickler & Howley, where he worked on securities, real estate, and tax litigation matters.

Among his many accomplishments, Peter has handled hundreds of voluntary disclosures of illicit corporate payments and securities enforcement matters both at the SEC and the DOJ, and successfully prosecuted the first transnational bribery cases brought by the Department. He played an important role in the enactment and subsequent amendments to the Foreign Corrupt Practices Act (FCPA), and was the Department's principal negotiator of the Organisation for Economic Co-operation and Development’s (OECD) anti-bribery convention and the Council of Europe Criminal Law Convention. He has worked closely with The World Bank and other international organizations in their implementation of anti-corruption compliance programs. Peter was a founder of the Justice Department's Securities and Commodities Fraud Working Group. As Deputy Chief of the Fraud Section, Peter was responsible for all of the Department's FCPA investigations and prosecutions, and for the FCPA Opinion Procedure. 

Peter was presented with the 1998 Award for Outstanding Government Lawyer by the American Bar Association Section of International Law and Practice for his role in enforcing the FCPA and in negotiating the OECD Convention.


Practice Areas

Anti-Money Laundering
Export Controls & Economic Sanctions
FCPA & International Anti-Corruption
Global Compliance & Risk Management
Business and Human Rights
Internal Investigations
White Collar & Internal Investigations

Kathryn Cameron Atkinson is the Chair of the International Department and a member of the firm’s Executive Committee.  Her practice focuses on international corporate compliance, including, in particular, the Foreign Corrupt Practices Act (FCPA), as well as export controls and economic sanctions, and anti-money laundering laws.  She advises clients on corruption issues around the world.  This advice has included compliance with the FCPA and related laws and international treaties in a wide variety of contexts, including transactional counseling, formal opinions, internal investigations, enforcement actions by the U.S. Department of Justice (DOJ) and the Securities and Exchange Commission (SEC) and resulting monitorships, as well as commercial litigation raising improper payment issues.  Ms. Atkinson served as the government-appointed Independent Compliance Monitor for KBR, Inc. in an FCPA matter settled with the DOJ and SEC.  She was a member of the original Transparency International task force that developed a compliance toolkit for small and medium-sized entities.  She co-produced, with Homer E. Moyer, Jr., “Comply But Compete,” a versatile, video-based FCPA training program.

On the compliance side of the practice, Ms. Atkinson focuses in particular on the design and implementation of custom-tailored international regulatory compliance programs for large and small companies in a wide range of industries.  Her compliance practice includes performing compliance due diligence in mergers and acquisitions, designing and performing compliance audits and assessments, training company personnel and third parties, and working with companies to design tailored safeguards in complex business transactions and relationships with third parties.

Ms. Atkinson’s recent accomplishments include creating and chairing an annual International Corporate Compliance Conference, sponsored by the Institute for International and Comparative Law (IICL) of the Center for American and International Law (CAIL).  The conference provides a coordinated discussion by government, in-house, and outside experts on key international compliance issues facing U.S. and multinational companies.  Ms. Atkinson is an active member of the Executive Committee of the CAIL and assists in designing continuing legal education (CLE) programs for foreign lawyers.

Ms. Atkinson speaks regularly on compliance at national conferences, is an active participant in International Bar Association (IBA), American Conference Institute (ACI), and other conferences on corruption, and has published articles regarding the FCPA and multilateral anti-corruption efforts and conventions.


Richard S. Levick, Esq. is Chairman & CEO of LEVICK, a global communications and public affairs firm that specializes in changing minds – representing countries and companies in the highest-stakes matters.

Mr. Levick is one of the industry’s most sought-after counselors and thought leaders. He has been named four times to the NACD’s list of “The 100 Most Influential People in the Boardroom,” has been named to multiple industry Halls of Fame, and is the co-author of four books. A regular commentator on television and major media, including regular appearances in Forbes and the Wall Street Journal, Mr. Levick is a powerful advocate for the ways in which every organization must think differently in the Digital Age.

LEVICK is a global communications and public affairs firm. When referring to Richard Levick it’s Levick, when referring to the firm it’s LEVICK.

BOOKS

• The Communicators: Leadership in the Age of Crisis
• Stop the Presses: The Crisis Litigation PR Desk Reference
• 365 Marketing Meditations
• Lessons for Absent Children


Stephanie Meltzer is a Vice President, Assistant General Counsel, at Pfizer. Inc. where she leads the Company’s global Anti-Corruption Program Office as well as the Mergers and Acquisitions Compliance function. Stephanie is a former federal prosecutor and partner at Cadwalader, Wickersham and Taft, where she specialized in advising companies and individuals in connection with white collar criminal matters as well as the development of international compliance programs. She has extensive experience with regard to the FCPA and its foreign law counterparts, having conducted numerous complex multi-jurisdictional investigations, performed transactional due diligence, and drafted and implemented anti-corruption compliance programs for a variety of companies and industries. Stephanie received her B.S. from the University of Michigan and a J.D. from Tulane University School of Law.


Timothy L. Dickinson is a partner in the Washington D.C. office of Paul Hastings with over 30 years’ experience in the field of anti-corruption law. Mr. Dickinson’s practice encompasses a number of areas, including all aspects of the Foreign Corrupt Practices Act, U.S. export laws, economic sanctions, ITAR regulations (including enforcement actions), and political risk insurance.

Mr. Dickinson works closely with a wide range of industries on FCPA matters, including establishment of compliance programs, due diligence in acquisitions, special investigations and defense before regulators in the U.S. as well as abroad, including the U.K.'s Serious Fraud Office. In 2005, he was appointed Independent Expert by Monsanto as part of a Deferred Prosecution Agreement with the Department of Justice and he recently concluded a three-year term as Independent Monitor in conjunction with a case settled in 2010.  Mr. Dickinson was also selected by the World Bank to assist with the development of their Voluntary Disclosure Program, and participated with Bank staff in evaluating and recommending improvements to a VDP participant's compliance program.  Chambers USA 2009, 2010, 2011, 2012 and 2013 have recognized him among the very few attorneys ranked as top-tier FCPA experts; he was also named by Ethisphere at the top of their FCPA 2009 list of Attorneys Who Matter.

Mr. Dickinson also represents political risk insurance entities dealing with coverage issues, arbitration of disputes, and recovery activities.  He has worked on major infrastructure projects in the Middle East and Asia and has represented foreign governments in matters involving public international law; including treaty rights, expropriation, and sovereign immunity.

Mr. Dickinson was an adjunct professor of law at Georgetown University Law Center from 1983 to 1993.  He is currently a Professor from Practice at The University of Michigan Law School where he teaches Transnational Law and International Commercial Transactions, and is a founding faculty member of the International Transactions Clinic, which gives students practical experience in international law. He served as the chair of the ABA Section of International Law and Practice in 1997-1998, has served on the Executive Council of the American Society of International Law and serves as Director of the International Law Institute’s course on government integrity and anti-corruption initiatives.  Mr. Dickinson is chairman of the ABA's International Legal Resource Center, which provides global legal assistance in conjunction with the United Nations Development Programme.  He served as Co-Chair of the International Bar Association's Anti-Corruption Committee for 2012-2013.

Mr. Dickinson graduated from The University of Michigan law school in 1979 after completing his B.A. in 1975.  He also studied at The Hague Academy of International Law in the Netherlands and L'Université d'Aix-Marseille in France and spent a brief period as an extern in the Office of the Legal Adviser of the Department of State.  Following law school, he earned his LL.M. as a Jervey Fellow at Columbia University.  After finishing his LL.M. degree, Mr. Dickinson worked in the Legal Service of the Commission of the European Communities in Brussels, Belgium.  Mr. Dickinson then returned to Washington, D.C., where he entered private practice.


PRACTICE AREAS

Ms. Wang heads the firm’ s complex disputes and investigations in beijing. She focuses her practice on various kinds of dispute resolution matters, through commercial litigation, arbitration and negotiation. She also has substantial experience with cross- border investigations and compliance, particularly in connection with anti- corruption, state secrecy and data privacy protection, and fraud.

REPRESENTATIVE MATTERS AND CASES

Commercial Dispute Resolution

  • Lead counsel on advising various investment banks in a series of disputes in connection with their investments in China.Disputes related to joint venture disputes, fraud, misappropriation of assets, misrepresentations in IPO applications and post-acquisition warranty and indemnity claims.
  • Represented a leading investment bank in various disputes arising from toll road projects in China before CIETAC and several Chinese courts.Disputes were related to joint venture contracts, loan agreements, and financial fraud.
  • Advised a leading steel producer in a shareholder derivative lawsuit, and disputes arising from equity transfer and joint venture agreements. Disputes concerned allegations of misrepresentation, misappropriation of assets and fraudulent financial statements.

OTHER INFORMATION

Professional Background

Ms. Wang used to work with a major international law firm and focuses her practice on various kinds of dispute resolution matters.  She has extensive experience in successfully representing foreign corporations and their China entities in resolving their disputes through negotiations, arbitration or litigation.  She also has substantial cross-border experience with investigations and compliance, particularly in connection with state secrecy and data privacy protection, anti-corruption and fraud.  In particular, she has advised some of the most high- profile cases in China with respect to PRC information compliance.

Ms. Wang is a native Mandarin speaker and is fluent in English.


A partner in the Litigation Department of Paul, Weiss, Rifkind, Wharton & Garrison LLP, Mark F. Mendelsohn is co-chair of the Anti-Corruption & FCPA Group, a member of the firm’s White Collar Crime and Regulatory Defense, and Securities Litigation Practice Groups. Prior to joining Paul, Weiss, Mr. Mendelsohn served as the deputy chief of the Fraud Section of the Criminal Division of the United States Department of Justice (DOJ), and is internationally acknowledged and respected as the architect and key enforcement official of DOJ’s modern Foreign Corrupt Practices Act (FCPA) enforcement program. He is widely known for dramatically increasing the level of sophistication of FCPA enforcement globally and for underscoring the importance of anti-corruption compliance. Prior to joining the Fraud Section, Mr. Mendelsohn was senior counsel in the DOJ’s Computer Crime and Intellectual Property Section in Washington, D.C., and prior to that served for nearly six years as an assistant U.S. attorney in the Southern District of New York.

PRACTICES

Litigation

Anti-Corruption & FCPA

Internal Investigations

Securities Litigation

White Collar Crime & Regulatory Defense

EDUCATION

J.D., University of Virginia School of Law, 1993

B.A., Yale University, 1989

CLERKSHIP

Hon. Denny Chin, U.S. District Court, Southern District of New York

RECOGNITIONS

Chambers

Lawdragon “500 Leading Lawyers in America”

The Best Lawyers in America

Who’s Who Legal


Philip Urofsky, a partner in the firm’s Litigation Group, is a former federal prosecutor with extensive experience investigating and prosecuting criminal and civil violations of the FCPA, the money laundering and mail and wire fraud statutes, and economic sanctions laws and regulations.  He advises clients on conducting internal investigations, designing and implementing compliance programs, as well as conducting due diligence in mergers & acquisitions, joint ventures, securities offerings, and concerning retention of third parties.

Additionally, Mr. Urofsky has extensive experience responding to and defending against federal, state, and international criminal, civil, and administrative investigations, prosecutions, and trials on behalf of both business entities and individuals. 

Prior to joining the firm, Mr. Urofsky served as a law clerk to the Honorable James M. Sprouse of the U.S. Court of Appeals for the Fourth Circuit and in a number of trial and supervisory positions within the U.S. Department of Justice’s Criminal Division where he handled all aspects of criminal prosecutions, including investigations, trials, and appeals.  While at the DOJ, Mr. Urofsky served as Assistant Chief of the Fraud Section, with responsibility for supervising or participating in virtually every FCPA investigation and prosecution. 

Mr. Urofsky was also a member of the United States’ delegation to the OECD Working Group on Corruption and was designated by the US as an expert in anti-corruption law and compliance for the Group’s peer review process.  As a DOJ attorney, Mr. Urofsky was the primary drafter of the Department’s Principles of Federal Prosecution of Corporations and lectured widely on corporate compliance issues.

Education

University of Virginia, J.D., 1988
Virginia Law Review, Articles Review Board
Order of the Coif

University of Virginia, B.A., 1985, with Highest Distinction

Bar Admissions/Qualifications

United States Supreme Court

District of Columbia, Virginia

United States District Court for Eastern District of Virginia

United States Courts of Appeals for the First, Third, Fourth, Fifth, and Sixth Circuits

Professional Affiliations and Business Activities

  • Committee Co-Chair, ABA Section on International Law, Anti-Corruption Initiatives and Compliance Issues Committee (2005-2007)
  • Steering Committee and faculty member, ABA National Institute on the Foreign Corrupt Practices Act (2006-present)
  • Guest lecturer, William & Mary Mason School of Business (2002-present)
  • Faculty member, ACI National Conferences on the Foreign Corrupt Practices Act, PLI Corporate Compliance Seminar, PLI White Collar Enforcement Seminar, IBA Anti-Corruption Conference, C5 Anti-Corruption Conference (Frankfurt), ABA FCPA Institute, ABA Securities Enforcement Institute
  • Advisory Committee, BNA White Collar Crime Report


Richard W. Grime is a litigation partner in the Washington office of Gibson, Dunn & Crutcher’s Washington, DC office and a member of the White Collar Defense and Investigations Practice Group and the Securities Enforcement Practice Group. 

Mr. Grime’s practice focuses on representing companies and individuals in corruption, accounting fraud, and securities enforcement matters before the Securities and Exchange Commission and the Department of Justice.  Mr. Grime also conducts internal investigations and counsels clients on compliance and corporate governance matters with a particular focus on corruption investigations.

Richard spent over nine years in the Division of Enforcement at the Securities and Exchange Commission in Washington, DC.  In his last four years at the Commission he was an Assistant Director.  While at the SEC, Mr. Grime supervised the filing of over 70 enforcement actions covering a wide range of the Commission’s activities including a series of FCPA cases including the first FCPA case involving SEC penalties for violations of a prior Commission order.

Richard is ranked as a nationwide "FCPA Expert" by Chambers USA 2011-2014 and Chambers Global 2012-2014.


Charles E. Duross is a partner in the Securities Litigation, Enforcement & White-Collar Defense Practice Group Morrison & Foerster LLP where he heads the firm’s global anti-corruption practice. Prior to joining the firm, Mr. Duross most recently served as a Deputy Chief of the Fraud Section in the Criminal Division of the U.S. Department of Justice, where he was in charge of all of the DOJ’s FCPA investigations, prosecutions and resolutions in the United States. Internationally recognized for his leading role in developing and implementing the government’s FCPA enforcement strategy, he was widely credited with developing the current enforcement regime, which, under his leadership, resolved more than 40 corporate cases, including two-thirds of the top 25 biggest corporate resolutions ever, resulting in approximately $1.9 billion in monetary penalties. During this time, the FCPA Unit also secured convictions of more than two dozen business executives and money launderers. Mr. Duross’s tenure was also marked by his efforts to make FCPA enforcement more transparent and compliance with the statute more understandable to the business community. Working closely with his counterparts at the U.S. Securities and Exchange Commission, Mr. Duross was one of the principal authors of the DOJ and SEC joint publication, A Resource Guide to the U.S. Foreign Corrupt Practices Act, which followed a series of consultations with business and compliance leaders. The FCPA Resource Guide has been described as a “landmark document,” an “FCPA hornbook,” and a “must-read for compliance officers.”

Mr. Duross also served as DOJ’s principal representative to the Organisation for Economic Co-operation and Development’s Working Group on Bribery for many years and helped develop the OECD’s acclaimed “Good Practice Guidance on Internal Controls, Ethics and Compliance.” Once dubbed “Mr. FCPA,” Mr. Duross is the recipient of the Attorney General’s Distinguished Service Award for the prosecution and conviction of Congressman Jefferson, the first Member of Congress ever charged with violating the FCPA, and the Assistant Attorney General’s Exceptional Service Award for leading the United States’ response to the OECD’s Phase 3 Review. Mr. Duross has been repeatedly recognized by the Ethisphere Institute as a “Government Star” among “Attorneys Who Matter,” and was identified by Law360 as one of “5 Prosecutors White Collar Attorneys Should Know” and by the Washington Post as one of five “Obama Officials to Watch” for business issues. Mr. Duross is an adjunct professor at Georgetown University Law Center where he teaches trial advocacy, and he has been a guest lecturer on foreign corruption issues at Harvard Law School’s Program on the Legal Profession and the University of Michigan’s Ross School of Business.


Claudius Sokenu, a former federal regulator with the Securities and Exchange Commission, is a partner in the firm’s Litigation Group where his practice focuses on representing financial institutions, public and private companies, accounting firms, and their Boards of Directors, Audit Committees, directors, officers, and employees in securities  enforcement actions and litigations, white collar criminal defense, derivative actions, internal investigations and crisis management, congressional investigations, and complex commercial litigations in state and federal courts. Claudius has extensive experience in handling delicate high-profile matters that require concurrent representation in the civil,  criminal,  and political spheres.

Earlier in his career, Claudius served in the Washington, DC office of the SEC’s Enforcement Division, on the Honors Program, first as a Staff Attorney and later as Senior Counsel, where he was responsible for handling a  broad range of domestic and international enforcement matters, including investigations involving accounting fraud, insider trading, initial public offerings, illicit payments under the FCPA, investment companies and investment advisers, market manipulation, and broker-dealer misconduct. He was also a member of the Enforcement Division’s  FCPA Working Group, which is now known as the FCPA Unit.

Consistently ranked by Chambers USA and Chambers Global for his investigative, regulatory, and securities enforcement practice, named a Litigation Star by Benchmark Litigation (2015), named a rising star by Ethisphere in its national annual rankings of “Attorneys Who Matter” (2012), named a “Top Lawyer” by The Network Journal (2011), recognized by Securities Law 360 as one of its 10 under 40 (2007), and named by Main Justice as one of the Best FCPA Lawyers Outside the Beltway (2011), Claudius has represented major companies and/or their officers and directors, including Allianz SE, Bank of New York, CIBC World Markets, GlaxoSmithKline, Bank of America, Ernst & Young Global, Avon Products, CVS Caremark, Arthur Andersen LLP, Amgen, Walmart, Bristol-Myers Squibb, Kraft Foods, Embraer, Cardinal Health, and TV Azteca before prosecutors and regulators in the United States and abroad and in federal and state courts on bet- the-farm matters.

Claudius Sokenu, a former federal regulator with the Securities and Exchange Commission, is a partner in the firm’s Litigation Group where his practice focuses on representing financial institutions, public and private companies, accounting firms, and their Boards of Directors, Audit Committees, directors, officers, and employees in securities  enforcement actions and litigations, white collar criminal defense, derivative actions, internal investigations and crisis management, congressional investigations, and complex commercial litigations in state and federal courts. Claudius has extensive experience in handling delicate high-profile matters that require concurrent representation in the civil,  criminal,  and political spheres.

Earlier in his career, Claudius served in the Washington, DC office of the SEC’s Enforcement Division, on the Honors Program, first as a Staff Attorney and later as Senior Counsel, where he was responsible for handling a  broad range of domestic and international enforcement matters, including investigations involving accounting fraud, insider trading, initial public offerings, illicit payments under the FCPA, investment companies and investment advisers, market manipulation, and broker-dealer misconduct. He was also a member of the Enforcement Division’s  FCPA Working Group, which is now known as the FCPA Unit.

Consistently ranked by Chambers USA and Chambers Global for his investigative, regulatory, and securities enforcement practice, named a Litigation Star by Benchmark Litigation (2015), named a rising star by Ethisphere in its national annual rankings of “Attorneys Who Matter” (2012), named a “Top Lawyer” by The Network Journal (2011), recognized by Securities Law 360 as one of its 10 under 40 (2007), and named by Main Justice as one of the Best FCPA Lawyers Outside the Beltway (2011), Claudius has represented major companies and/or their officers and directors, including Allianz SE, Bank of New York, CIBC World Markets, GlaxoSmithKline, Bank of America, Ernst & Young Global, Avon Products, CVS Caremark, Arthur Andersen LLP, Amgen, Walmart, Bristol-Myers Squibb, Kraft Foods, Embraer, Cardinal Health, and TV Azteca before prosecutors and regulators in the United States and abroad and in federal and state courts on bet- the-farm matters.

Bar Admissions

New York

District  of Columbia

Education

Georgetown University Law Center, LLM in Securities  and Financial Regulation

London School of Economics  and King’s College London, University of London, LLM in Commercial  and Corporate Law

South Bank University, London, LLB, Upper Class  Honors


F. Joseph Warin is chair of the Washington, D.C. Office's Litigation Department, which consists of over 125 attorneys.  Mr. Warin also serves as co-chair of the firm's White Collar Defense and Investigations Practice Group.  He served as Assistant United States Attorney in Washington, D.C. from 1976-83.  In that capacity, Mr. Warin was awarded a Special Achievement award by the Attorney General.  As a prosecutor, he tried more than 50 jury trials.  Mr. Warin's areas of expertise include white collar crime and securities enforcement – including Foreign Corrupt Practices Act investigations, False Claims Act cases, special committee representations, compliance counseling and complex class action civil litigation.  Mr. Warin has handled cases in more than 35 states.  His clients have included corporations, officers, directors and professionals in regulatory, investigative and trial matters. These representations have involved federal regulatory inquiries, criminal investigations and Congressional hearings.  Mr. Warin successfully argued motions to dismiss in securities and consumer protection class actions in the Southern District of New York and the District of Columbia.  Mr. Warin's civil practice includes representation of clients in complex litigation in federal courts and international arbitrations.  He has tried 10b-5 securities and RICO claim lawsuits, hostile takeovers, and commercial disputes.  Mr. Warin has handled numerous class action cases and has defended class actions in several district courts including the Southern District of New York, District of Columbia, Eastern District of Missouri and Northern District of California.  These representations include investment banking firms, Big 4 accounting firms, broker-dealers and hedge funds. For many years, Mr. Warin has been hired by audit committees or special committees of public companies to conduct investigations into allegations of wrongdoing.  These investigations have been in a wide variety of industries including energy, oil services, healthcare, and telecommunications.


Greta Lichtenbaum, a partner in the Washington, D.C. office, has been advising clients on anti-corruption compliance for over two decades, and has worked with clients in a range of business sectors, including defense, energy, finance, high-tech, and pharmaceuticals.  As the U.S. Government’s expectations concerning FCPA compliance programs have increased, Greta has worked closely with clients as they enhance and refine their compliance mechanisms to mitigate corruption risk. In addition to the FCPA, she has deep experience in the area of economic sanctions and export control laws. She has often been asked to develop parallel compliance mechanisms to mitigate both anti-corruption and trade controls risks, and understands how these areas of risk inter-relate.  Greta is ranked in both Chambers USA and Chambers Global.   She is a frequent speaker on legal issues at business groups and bar associations.  Greta received her law degree from Harvard University in 1990.


Harry Chernoff has been an Assistant United States Attorney in the Southern District of New York, Criminal Division, since 2002. He currently serves as Senior Litigation Counsel in the Office’s Securities and Commodities Fraud Task Force. He has investigated and prosecuted offenses that include securities fraud, money laundering, racketeering, tax evasion, violations of the Foreign Corrupt Practices Act (AFCPA@), violations of the International Emergency Economic Powers Act (AIEEPA@), terrorism, and murder.

Among the cases Mr. Chernoff has tried to verdict for the Government are the following: in 2013, United States v. Michael Steinberg, in which the defendant, a portfolio manager at the hedge fund SAC Capital, was convicted of insider trading; in 2012, United States v. Joseph Collins, in which the defendant, a partner at an international law firm and outside counsel to Refco, Inc., was convicted of securities fraud in a re-trial; in 2010, United States v. Ahmed Ghailani, in which the defendant, the only Guantanamo Bay detainee to be tried in an Article III court to date, was sentenced to life in prison for his participation in Al Qaeda=s 1998 bombing of American embassies in Kenya and Tanzania. In 2011, Mr. Chernoff received the Attorney General=s Distinguished Service Award, the Justice Department’s second-highest annual award.

Mr. Chernoff’s work in the FCPA area includes the 2013 prosecution of several employees of a Wall Street brokerage who pled guilty in connection with the payment of kickbacks to a Venezuelan development bank official who directed trading business to the defendants. In 2009, Mr. Chernoff was selected by the American Lawyer as a A Litigator of the Week@ for his representation of the Government in United States v. Frederic Bourke, in which the defendant, an investor in Azerbaijani privatization, was convicted at trial of conspiracy to violate the FCPA. Mr. Chernoff also argued the subsequent appeal for the Government, United States v. Viktor Kozeny.

Mr. Chernoff previously practiced at Davis Polk & Wardwell in New York and was a law clerk to the Honorable Amalya L. Kearse of the U.S. Court of Appeals for the Second Circuit. Prior to entering law school, Mr. Chernoff served as a legislative assistant to then-U.S. Representative Charles Schumer of New York and was an Urban Fellow in the Office of the Mayor of the City of New York. Mr. Chernoff is a graduate of Harvard Law School and Harvard College, and he was a visiting student at the University of Delhi, India. He has lectured around the United States and abroad on the FCPA, securities fraud, terrorism, and other criminal law topics.


KIMBERLY A. PARKER is a partner at Wilmer Cutler Pickering Hale and Dorr in Washington.  Ms. Parker co-leads the firm’s Foreign Corrupt Practices Act (FCPA) and Anti-Corruption Practice.  She has represented companies and individuals in a variety of FCPA enforcement matters, including defense company Armor Holdings in its July 2011 FCPA settlement involving conduct related to the United Nations, oil driller Helmerich & Payne in its July 2009 FCPA involving payments to customs officials in Argentina and Venezuela, and the Titan Corporation in its landmark 2005 FCPA case.  She has conducted internal investigations in the United States, Asia, Africa, Europe, and Latin America.  She regularly counsels clients on FCPA compliance, assists in developing and conducting FCPA training and compliance programs, and conducts anti-corruption due diligence and risk assessments.  In addition to co-authoring several articles on the FCPA, Ms. Parker is a co-author, with Roger M. Witten and Jay Holtmeier of the firm’s New York office, of a leading treatise in the field, Complying with the Foreign Corrupt Practices Act.  Ms. Parker is ranked for FCPA work in Chambers USA: America's Leading Lawyers in Business.


LUCINDA A. LOW is a partner in the Washington, DC office of Steptoe & Johnson LLP, where she heads the firm's Chambers-ranked FCPA and anti-corruption practice and its Compliance, Investigations, Trade and Enforcement Department. Her white collar practice focuses on the U.S. Foreign Corrupt Practices Act and other anti-corruption laws, as well as other laws and regulations, including economic sanctions and AML laws, that have an extraterritorial impact on multinational businesses, as well as multijurisdictional regulatory and enforcement matters. Ms. Low has extensive experience in internal and government investigations involving their overseas businesses, representing companies, Audit Committees and Board of Directors, and individuals.  She represents clients in enforcement matters before the U.S. Department of Justice, Securities and Exchange Commission, and the World Bank and other international financial institutions. Ms. Low's practice also includes compliance counselling and representation in investment disputes between commercial parties and host governments, including disputes involving issues of fraud and corruption.  She received a #1 Ranking, Chambers Global 2010-2015, International Trade: FCPA Experts.  Ms. Low is listed in Best Lawyers in America 2012-2015, International Arbitration: Government and International Trade and Finance Law. Ms. Low is in Washington, DC Super Lawyers, International, 2014-2015.

Ms. Low is a member of the Board of Directors of Transparency International-USA and serves on its Executive Committee, and has received numerous awards for her work in this area.  In fact, the Global Investigations Review has named her recently to its 2015 “Women in Investigations:  One Hundred Investigation Specialists from Around the World.”  Ms. Low is a Presidential appointee to the Panel of Conciliators of the International Centre for the Settlement of Investment Disputes.  She also currently serves on the secretary of state’s advisory committee on international law and is president-elect of the American Society of International Law.  Ms. Low speaks Portuguese, Spanish and French, and has some knowledge of Russian, Italian and Japanese.


Richard N. Dean is the Managing Partner of the Washington, D.C. office of the international law firm of Baker & McKenzie LLP. 

Mr. Dean specializes in the U.S. Foreign Corrupt Practices Act (FCPA) and related legislation, including U.S. money laundering laws and their application to the activities of U.S. companies in emerging markets. He advises on the structuring of foreign investment transactions to comply with U.S. laws; supervises the conduct of internal investigations and audits to determine compliance with laws and regulations, including the Sarbanes-Oxley Act; and advises senior management and corporate audit committees on the consequences of such investigations and audits, including the development of appropriate defenses, disclosures, disciplinary actions and compliance policies.   His practice includes representing multinational companies before the U.S. Department of Justice and the Securities and Exchange Commission in connection with FCPA and related matters.

Mr. Dean has conducted investigations into possible FCPA violations in a variety of high risk emerging markets, such as Russia, Ukraine and other CIS countries, West Africa, the Middle East, China, India and Indonesia and has advised multinational companies on structuring transactions with distributors, dealers, joint venture partners and charitable institutions.


Rob deButts is a Vice President in the Goldman, Sachs & Co. Financial Crime Compliance group, engaged principally on anti-bribery matters. He also has worked in the firm’s Business Intelligence Group. Prior to joining Goldman Sachs, he practiced law in the corporate, banking and business department at Fulbright & Jaworski L.L.P., most recently as senior counsel. Rob earned a B.A. in History from Yale University and a J.D. from the University of Virginia.


Stephen Zimmermann is the Director of Operations for the World Bank Integrity Vice Presidency (INT).  Mr. Zimmermann directs a multi-disciplinary team of lawyers, investigators, forensic accountants, analysts and anti-corruption experts charged with detecting, investigating, sanctioning and preventing fraud and corruption in Bank-financed activities around the world.  Since assuming his position, he has had a leading role in developing and implementing an expanded strategy for the World Bank’s integrity agenda, including the introduction of negotiated resolutions of investigations, reforms to the World Bank’s sanctions process, expansion of joint investigations with national authorities, introduction of restitution and enhancements to the Voluntary Disclosure Program.  In addition, he led efforts to reach a historic Cross-Debarment Agreement signed by the World Bank and four leading regional Multilateral Development Banks for mutual enforcement of sanctions decisions. 

Prior to joining the World Bank Group, Mr. Zimmermann was the first former Chief of the Office of Institutional Integrity for the Inter-American Development Bank where he led the creation of the –then- new unit and its positioning in the Latin America region and the global anticorruption community. He also has served as the interim Chief of Staff for the Independent Inquiry Committee into the United Nations Oil for Food Program.  Mr. Zimmermann has previously worked as the Senior Policy Officer and Senior Counsel for the World Bank’s Department of Institutional Integrity, the predecessor to the Integrity Vice Presidency.
 
From 1991 until 1999, Mr. Zimmermann was an Assistant United States Attorney in the District of Maryland. During his tenure as a federal prosecutor, he successfully prosecuted numerous complex cases involving corruption, financial fraud, tax evasion, health care fraud, securities fraud, and money laundering. He has worked closely with major federal law enforcement agencies, as well as prosecuting offices overseas.

Prior to joining the United States Attorney’s Office, Mr. Zimmermann worked as an attorney with Wilmer, Cutler & Pickering. His practice involved matters involving securities fraud, white-collar criminal matters and a variety of commercial civil litigation.


Tim Coleman is a partner in the Washington, D.C. office of Freshfields Bruckhaus Deringer. He handles government investigations and related litigation, with a focus on international cases. Tim's career spans more than two decades, including eight years with the U.S. Department of Justice. As a federal prosecutor in the Southern District of New York, he specialized in white-collar crime, and was a member of the U.S. Attorney's Securities and Commodities Fraud Task Force. As Senior Counsel to the Deputy Attorney General of the United States in Washington, he was responsible for the President's Corporate Fraud Task Force. Before joining Freshfields, Tim was co-chair of the white-collar practice at one of the largest global law firms based in New York. He has testified before the U.S. Congress, and his views on white-collar crime issues have appeared in the Wall Street Journal, the Financial Times and other leading publications.


William F. McGovern focuses his practice on international commercial disputes, international regulatory and criminal investigations, as well as matters involving worldwide asset-tracing and international judgment enforcement.  Mr. McGovern regularly represents private and institutional clients in U.S. government investigations into allegations concerning securities law violations, antitrust, Foreign Corrupt Practices Act ("FCPA"), money laundering, corporate accounting fraud, and various other laws with international applications. In addition, Mr. McGovern often conducts confidential internal investigations on behalf of executive boards and committees of international public and private companies.

Mr. McGovern has been globally ranked in leading professional directories, including Chambers Asia Pacific, as “an efficient, highly intelligent, and solution-oriented practitioner.”  He is regularly called upon to lecture about and publish in the areas of cross-border government enforcement, as well as the global regulatory climate with a particular emphasis on the interaction between the U.S. and Asia.

Prior to joining Kobre & Kim, Mr. McGovern worked as a senior litigator and Executive Director for Morgan Stanley in Asia and the U.S.  As a member of the Regulatory Group at Morgan Stanley, managed a team of lawyers based in Hong Kong, Sydney, Tokyo and Mumbai.  He regularly represented Morgan Stanley in regulatory investigations and established and implemented enhanced compliance policies and procedures that were required by their regulators as part of various settlements.  Earlier in his career, Mr. McGovern served as Branch Chief in the Enforcement Division of the U.S. Securities and Exchange Commission in Washington DC and New York, and as an Assistant District Attorney in New York.


Erich Grosz is a counsel with Debevoise & Plimpton LLP whose practice focuses on white collar criminal defense, internal investigations, compliance advice, and complex commercial litigation.  He has represented companies and individuals in criminal, civil, and SEC investigations and enforcement proceedings involving allegations, among others, of violations of the U.S. Foreign Corrupt Practices Act, securities and accounting fraud, and employee misconduct.  He also regularly advises companies on compliance risks, policies, and procedures.  Mr. Grosz is also the co-managing editor of FCPA Update, the firm's monthly newsletter addressing developments in anti-corruption law enforcement and related compliance topics.  Prior to joining the firm, Mr. Grosz served as a law clerk to the Honorable Alvin K. Hellerstein, U.S. District Court for the Southern District of New York, and to the Honorable Chester J. Straub, U.S. Court of Appeals for the Second Circuit.


Mr. Rowsey is the Chief Executive Officer of Compatriot Capital, Inc., a real estate investment company based in Dallas, Texas.  Prior to joining Compatriot, he was a founder and the managing partner of E2M Partners, LLC, a sponsor and manager of private real estate equity funds, and an affiliate of Compatriot. Mr. Rowsey continues to serve as Chairman of E2M. He previously served as a member of the Board of Trust Managers of Crescent Real Estate Equities Company, a real estate investment trust, and as currently serves as Non-Executive Chairman of the Board of Directors and Chairman of the Nominating and Governance Committee of Ensco plc, (NYSE: ESV), an international offshore oil field service and drilling company based in London.  Mr. Rowsey is a member of the Board of Directors of Powdr Corporation, one of the largest alpine resort and outdoor sports companies in the United States, KDC Holdings, a national real estate investment and commercial development firm, Village Green Holding, a multi-family housing management and investment firm, JLB Partners, a national multi-family development and construction firm, and Amicus Investors, an investment firm focused on higher education infrastructure. He also serves on the Board of Trustees of the Highland Park Independent School District and is past Chairman of The Real Estate Council.  Mr. Rowsey is a magna cum laude graduate of Duke University and a cum laude graduate of the Southern Methodist University School of Law.


Raja is responsible for the company’s Compliance program, including Financial Crimes Compliance, as well as other global risk responsibilities.  He also participates in Tishman Speyer’s Investment and Management Committees.

Raja previously worked at Morgan Stanley for ten years as the Global Head of the Anti-Corruption Group, the Global Head of Special Investigations, and the Firm’s Global Franchise Committee Officer.

Prior to joining Morgan Stanley, Raja was a prosecutor for ten years, most recently at the Department of Justice, Criminal Division, Fraud Section, in Washington, DC.  Raja also served as an Assistant District Attorney at the New York County District Attorney's Office.