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Insider Trading Law 2019


Speaker(s): Andrew Bauer, Antonia M. Apps, Benjamin Naftalis, Brian A. Jacobs, Cynthia B. Adams, David I. Miller, Eugene Ingoglia, Harris Fischman, Jason Cowley, Kan M. Nawaday, Manal Sultan, Matthew L. Schwartz, Rebecca Monck Ricigliano, Simona Suh
Recorded on: Oct. 30, 2019
PLI Program #: 247786

Antonia M. Apps is a former federal prosecutor and nationally recognized trial attorney with experience in criminal and civil matters. She represents financial institutions, corporations, and executives in regulatory enforcement proceedings, white-collar criminal investigations, complex commercial litigation and internal investigations. She is also a lecturer at Harvard Law School on white collar criminal law and procedure. Prior to joining Milbank, Ms. Apps served as an Assistant U. S. Attorney in the Southern District of New York, where she led many of the government’s highest-profile insider trading cases, including the prosecution of S.A.C. Capital Advisors. She was also the lead prosecutor at trial and on appeal in the landmark case of United States v. Newman.  Ms. Apps prosecuted over 20 insider trading defendants and tried numerous securities fraud trials. In 2019, Ms. Apps was named to Crain’s New York Business’ “Notable Women in Law” list. The list recognizes the brightest and boldest legal minds of New York City based on both distinguished careers and exceptional civic and philanthropic activities.  Lawdragon has named Ms. Apps in its list of 500 Leading Lawyers in America each year since 2014, and she is ranked in the Chambers USA listing for White-Collar Crime & Government Investigations, among other industry recognitions.


Andrew Bauer is a law partner in the White Collar Defense and Securities Enforcement and Litigation practice groups at Arnold & Porter.  His practice involves defending organizations and individuals facing criminal and civil allegations of fraud and other misconduct in the financial services, healthcare, and other industries.  Prior to joining the private sector, Mr. Bauer served as an Assistant United States Attorney with the Criminal Division of the United States Attorney's Office for the Southern District of New York.  There he was a member of the Securities and Commodities Fraud Task Force, where he focused primarily on securities fraud, insider trading, investment advisor fraud, market manipulation, money laundering, and Foreign Corrupt Practices Act (FCPA) violations.  Throughout his career, Mr. Bauer has worked closely with the multiple governmental agencies regulating much of today's commercial activity, including the SEC, CFTC, FTC, FINRA, and FDA.  Before becoming an attorney, Mr. Bauer worked as a trader and analyst in the convertible bond and risk arbitrage groups at a hedge fund, as well as a project leader for an Internet venture company.  Mr. Bauer studied at the University of Pennsylvania (the Wharton School) and the University of Michigan Law School.


Cynthia B. Adams is Managing Director and Head of Litigation, Regulatory and Employment Legal at Jefferies LLC, a global investment banking firm.  She leads the team responsible for a wide array of litigation, enforcement, and employment matters, including internal investigations, regulatory and compliance advice, and firm-wide policy initiatives. 

Prior to Jefferies, Cynthia held senior in-house legal roles at Morgan Stanley and Citigroup Global Wealth Management.  She joined Citigroup from WilmerHale, where she represented financial institutions in regulatory investigations and other matters.  Prior to WilmerHale, she served as an enforcement attorney in the New York office of FINRA (then NASD Regulation).  Cynthia began her legal career at Sullivan & Cromwell, following a federal clerkship in the U.S. District Court for the District of Columbia. 

She earned her law degree with honors from Howard University School of Law, where she was Editor-in-Chief of the Law Review, and her undergraduate degree from the College of William & Mary.

Cynthia serves on the Executive Committee of the Compliance and Legal Society for the Securities Industry and Financial Markets Association (SIFMA), the leading industry group for the financial services industry.  She is also a member of the American Bar Association and the National Bar Association.  She is a Life Fellow of the American Bar Association and an advisory board member for Corporate Counsel Women of Color (CCWC).  She frequently speaks on panels regarding ethics for legal and compliance professionals, best practices for regulatory and internal investigations, and success strategies for diverse counsel.  

Cynthia currently serves on the Board of Directors of Volunteers of Legal Services (VOLS), a leading provider of pro bono legal services to New York City’s neediest residents.  She is also a member of the Board of Directors of the Northside Center for Child Development, a non-profit providing expert behavioral, mental health, education and enrichment programs to economically disadvantaged children and families in Harlem and Brooklyn.  At Jefferies, she has served on the Steering Committee of jWIN, the firm’s women’s leadership initiative, and on the Steering Committee for J-NOBLE, the Jefferies Network of Black and Latino Employees. 

 


Eugene Ingoglia is a partner in the investigations and litigation practice at Allen & Overy LLP. His practice focuses on criminal, civil and regulatory securities and anti-corruption matters. He has extensive experience in handling sophisticated securities and business crime matters and has achieved notable results for a wide variety of clients over the course of his career, including successfully persuading the SEC not to pursue insider trading charges against two different clients over the past year.  He has represented entities and individuals in actions and investigations by various U.S. Attorney's Offices, the SEC, the CFTC, FERC, and FINRA as well as other federal and state regulatory agencies, involving allegations of insider trading, securities fraud, accounting fraud, market manipulation, FCPA violations, money laundering and healthcare fraud.  In addition, Gene has represented numerous clients at trial against the SEC and the U.S. Attorney’s Office, including a hedge fund portfolio manager in the recently completed “political intelligence” insider trading criminal trial in the Southern District of New York.

Previously, Gene was an Assistant U.S. Attorney for the Southern District of New York and a member of the Securities and Commodities Fraud Unit, serving as the lead attorney in numerous federal jury trials and complex white collar investigations. In that position, he represented the government in the trial and conviction of former SAC Capital portfolio manager Mathew Martoma in the largest insider trading scheme ever charged; and conducted the investigation that led to the conviction of former bank executives and traders for deliberately overstating the value of certain real estate backed securities, one of the few successful criminal prosecutions arising out of the financial crisis.

Gene has tried more than a dozen federal criminal cases and briefed and argued numerous appeals before the U.S. Court of Appeals for the Second Circuit.


Manal Sultan is currently the Deputy Director for the Division of Enforcement and is in charge of the Division’s New York office. Ms. Sultan represented the Division in many enforcement actions, including virtual currency matters, which are filed in the United States District Court and focus on allegations of manipulation, fraud, and trade practice misconduct. She has also successfully negotiated and settled many actions including benchmark cases and spoofing cases. Prior to being appointed Deputy Director, she has served as a chief trial attorney with the Division of Enforcement at the CFTC in New York. She also served as the Squad Leader of the Manipulation and Disruptive Trading squad of the Division. Ms. Sultan is a graduate of Fordham Law School. In addition, she holds an MBA in finance and information technology.

 


Matthew Schwartz is a Partner in Boies Schiller Flexner’s New York City office. His practice  focuses on government and internal investigations, white collar defense, regulatory compliance, and complex civil litigation. A “buttoned-up assassin in the courtroom” praised by his colleagues for his “laser-like focus and precision,” Mr. Schwartz has a reputation for “possessing the consistent ability to take knotty issues and distilling them to their essence” (Forbes, 2014). “Talented and extremely hardworking” (Legal 500, 2017), he has first-chaired numerous jury and non-jury trials and personally argued more than a dozen federal appeals.

From 2005 to 2015, Mr. Schwartz was a federal prosecutor in the Southern District of New York, “where he spent a decade leading blockbuster trials” (Crain’s, 2017). As a member of that office’s Securities and Commodities Fraud Task Force, Mr. Schwartz led a number of high-profile matters, including the investigations and deferred prosecution agreements with JPMorgan and Commerzbank AG on BSA/AML charges; the investigation and prosecutions related to the “London Whale”  trades; and all aspects of the government’s investigation of Bernard L. Madoff Investment Securities, including a six-month long jury trial and the forfeiture of more than $9 billion. He conducted numerous investigations in parallel with regulators such as the SEC, CFTC, OCC, Federal Reserve Board, FinCEN, OFAC, and PCAOB; state Attorneys General and other state regulators, such as  the New York State Department of Financial Services; and foreign regulators and law enforcement, such as the UK Financial Conduct Authority.

Mr. Schwartz has frequently been recognized for his work. He was named as one of Crain’s New York Business “40 Under Forty” (2017); Law 360 named him to its “Top Attorneys Under 40” list  in 2016. And Ethisphere in 2015 and 2016 named him to its list of “Attorneys Who Matter.” He is a three-time recipient of the Department of Justice’s John Marshall Award – the highest award given by the Department to lawyers – and was named in 2013 as Prosecutor of the Year by the Federal Law Enforcement Foundation.

Education:

  • Columbia Law School, J.D.
  • Columbia College, B.A.

Former Positions:

  • Assistant U.S. Attorney
  • Law Clerk to Hon. Thomas J. Meskill (2d Cir.) and Shira A. Scheindlin (S.D.N.Y.)
  • Special Master, In re IPO Securities Litigation


A partner in the Litigation Department, Harris Fischman is a former federal prosecutor who focuses his practice on regulatory enforcement proceedings, internal investigations, criminal defense and trial work. An experienced trial and appellate lawyer, Harris handles all stages of civil and criminal investigations and proceedings.

Harris previously served as an Assistant U.S. Attorney in the U.S. Attorney's Office for the Southern District of New York, where he was Chief of the Violent and Organized Crime Unit and Deputy Chief of the Narcotics Unit. During his six years there, he led the investigation and prosecution of a wide range of federal crimes, including financial fraud, money laundering, public corruption, asset forfeiture, racketeering and murder. An accomplished trial lawyer, Harris has successfully conducted 15 criminal and civil trials. As a prosecutor, Harris also supervised more than 30 criminal trials.

Harris has represented various companies in:

  • SEC investigations, including investigations into alleged accounting and disclosure fraud, insider trading, supervisory failures and various controls issues;
  • criminal investigations by state and federal authorities, including investigations into alleged insider trading and fraud;
  • criminal and civil FCPA investigations by the SEC and the DOJ; and
  • complex civil litigation, including representing medical device and diagnostic company Alere, Inc. in a multi-billion dollar M&A litigation.

Harris also regularly represents:

  • individuals in regulatory and criminal investigations, including several investigations into alleged insider trading; and
  • boards in various matters, including internal investigations and corporate governance issues.

Harris is a frequent speaker on various issues related to regulatory enforcement proceedings and criminal law. He recently taught a seminar on federal prosecution at NYU School of Law. Harris also served as a law clerk at the Office of the Prosecutor of the International Criminal Tribunal for the Former Yugoslavia, where he worked on the prosecution of Slobodan Milosevic, the former president of Yugoslavia, for attempted genocide and other war crimes.


A seasoned trial lawyer and former federal prosecutor, David I. Miller practices in the areas of white collar criminal defense, government and internal investigations, securities and commodities enforcement, related complex civil litigation, cryptocurrency, and national security. Previously, David served for five years as an Assistant US Attorney in the Southern District of New York (SDNY), over half that time as a member of the Securities and Commodities Fraud Task Force. He also served as a terrorism prosecutor with the Department of Justice in Washington, DC, as a Special Assistant US Attorney in the Eastern District of Virginia, as an Assistant General Counsel for the Central Intelligence Agency, and as a securities and commercial litigation attorney in private practice.

David has more than two decades of litigation experience, including in white collar criminal defense; securities and commodities litigation and enforcement proceedings; corporate internal investigations (including those implicating the Foreign Corrupt Practices Act); complex commercial litigation; Bank Secrecy Act and anti-money laundering issues; cryptocurrency issues; forfeiture litigation; compliance counseling; and national security matters. David has conducted 10 jury and bench trials, several of which were multi-defendant trials, including securities and accounting fraud trials, with guilty verdicts secured for nearly all defendants on all counts. As an appellate advocate, David has briefed and argued several appeals before the US Court of Appeals for the Second Circuit. The Legal 500 US notes that David has been praised by industry insiders for his “sharp mind, strategic thinking and client-focused advice,” and he has been recognized as a New York Super Lawyer in the area of white collar criminal defense.

As an Assistant US Attorney in SDNY’s Securities and Commodities Fraud Task Force, David was responsible for investigating and prosecuting a wide range of securities and commodities fraud offenses, including insider trading, investment adviser fraud, offering fraud, accounting fraud, options backdating, market manipulation, reverse mergers, credit default swap schemes, hedge fund improprieties, and Ponzi schemes. David handled multiple insider trading matters and was part of a team of prosecutors leading the government’s investigation and prosecution of Operation Perfect Hedge, which has resulted in the conviction of more than 80 individuals for insider trading offenses since 2009. As part of his duties, he worked closely with, and coordinated parallel civil enforcement proceedings with, the SEC, CFTC, FINRA, and other regulatory agencies. While David was an Assistant US Attorney, he also prosecuted numerous other criminal offenses, including bank, mail, wire, healthcare, and tax fraud; credit card fraud and identity theft; money laundering; obstruction of justice and false statements; terrorism offenses; export control violations; and narcotics, firearms, and robbery offenses. Additionally, he has experience with asset forfeiture issues, having litigated several criminal and civil forfeiture proceedings.

David previously served as a terrorism prosecutor with the US Department of Justice’s Counterterrorism Section in Washington, DC, where he investigated and prosecuted several high-profile terrorism-related cases through trial. He also served as a Special Assistant US Attorney in the Eastern District of Virginia, where he investigated and prosecuted white collar, firearms, narcotics, and gang-related offenses through trial.  David’s career includes his time as an Assistant General Counsel for the Central Intelligence Agency, where he litigated and prosecuted cases on the CIA’s behalf (including classified and state secrets matters); was the assigned CIA representative to the prosecution team in United States v. I. Lewis (“Scooter”) Libby (D.D.C.); regularly advised senior CIA officials; and represented the CIA at high-level, interagency meetings implicating sensitive national security issues.  Before joining government service in 2005, David spent six-and-a-half years as a securities, complex commercial and bet-the-company litigator with two large law firms in New York.

David’s experience in defending allegations of financial, securities, and commodities fraud is invaluable for clients—including broker-dealers, hedge funds, private equity funds, investment companies and advisers, banks, and public and private companies—facing risks of government investigation, regulatory enforcement, and related civil litigation, as well as other matters that require internal investigations, including Foreign Corrupt Practices Act and Bank Secrecy Act/Anti-Money Laundering compliance. To this end, David represents clients before DOJ, several US Attorney's Offices, SEC, CFTC, FINRA and other self-regulatory organizations, state attorneys general offices, and other state regulators and enforcement authorities. He is also an asset for clients facing issues implicating digital currencies, national security, international clients doing significant business in the United States, and clients with cybersecurity and privacy-related issues.  David is also a technical advisor for a popular television drama series.


Benjamin Naftalis is the Global Co-Chair of the White Collar Defense & Investigations Practice and a partner in the Litigation & Trial Department of Latham & Watkins.

A former federal prosecutor, Mr. Naftalis is a trial lawyer who represents financial institutions, corporations, and individuals in white collar criminal defense and regulatory matters, internal investigations, complex civil litigation, and a range of other sensitive situations, throughout the US and internationally.

Prior to joining Latham, Mr. Naftalis served as an Assistant United States Attorney in the Southern District of New York from 2006 to 2014. As a member of the Southern District’s Securities and Commodities Fraud Task Force, Mr. Naftalis investigated and prosecuted a wide range of white collar matters related to insider trading, accounting fraud, market manipulation and pump-and-dump schemes, broker-dealer and investment advisor fraud, mismarking of securities, dark pools, high-frequency trading, and cryptocurrencies.

As a member of the Southern District’s Terrorism and International Narcotics Unit, Mr. Naftalis led many of the government’s highest-profile extraterritorial investigations involving terrorism and national security, international money-laundering, and global narcotics trafficking that targeted senior al Qaeda and al Shabaab operatives and narcotics kingpins. He has deep experience conducting investigations in parallel with US and foreign law-enforcement, intelligence services, and regulators, including the FBI, SEC, CFTC, FINRA, OFAC, DEA’s Special Operations Division, Department of Defense, Department of State, and High-Value Detainee Interrogation Group.

Mr. Naftalis is also an experienced first-chair trial and appellate lawyer. He has tried eight federal jury trials, and briefed and argued more than 10 appeals before the US Court of Appeals for the Second Circuit, including addressing questions of first impression related to challenges to the extraterritorial reach of securities fraud prosecutions.

Mr. Naftalis is recognized by Chambers USA and The Legal 500 US in the areas of white-collar criminal defense and government investigations. In 2016, he was named to Law360’s list of Rising Stars in the White Collar area, and recognized as a Rising Star by the New York Law Journal. In 2012, Mr. Naftalis received the US Attorney General’s Award for Distinguished Service — the Department of Justice’s second highest award.

Prior to joining the US Attorney’s Office, Mr. Naftalis clerked for Judge Jed S. Rakoff of the US District Court for the Southern District of New York and Judge Dennis Jacobs of the US Court of Appeals for the Second Circuit.

He began his career as a corporate development analyst at DoubleClick, a technology company later acquired by Google.

Mr. Naftalis is a term member of the Council on Foreign Relations.


Brian A. Jacobs, a partner at Morvillo Abramowitz Grand Iason & Anello PC, is a former federal prosecutor and an experienced trial and appellate lawyer who represents individuals and organizations in criminal, civil, and regulatory matters, internal investigations, and appeals. His cases have involved allegations of financial fraud, antitrust violations, accounting fraud, insider trading, bribery and corruption, computer hacking, and trade-secrets theft.

Brian previously served as an Assistant U.S. Attorney in the U.S. Attorney’s Office for the Southern District of New York, where he was Deputy Chief of Appeals. During his six and a half years at the U.S. Attorney’s Office, Brian led the investigations and prosecutions of a wide range of federal crimes, including bank, wire, mail, and securities fraud, public corruption, money laundering, obstruction of justice, embezzlement, and cybercrime. As a prosecutor, Brian successfully conducted nine jury trials, including multiple high-profile public corruption matters and complex white-collar cases. He also argued ten appeals before the United States Court of Appeals for the Second Circuit, and as Deputy Chief of Appeals, he co-authored briefs and supervised oral arguments in more than 50 appellate cases.

In 2017, Brian was named a white collar “Rising Star” by Law360, which recognizes “attorneys under 40 whose legal accomplishments transcend their age.” In 2016, Brian was named a “Rising Star” by the New York Law Journal, which recognizes “attorneys 40 and under who have established a record of accomplishments and demonstrated that they are top contributors to the practice of law and their communities.” The Law Journal acknowledged Brian for handling “an impressive roster of headline-producing cases and successful prosecutions of corruption and other criminal cases” as a federal prosecutor. The Legal 500 United States has recommended Brian in the area of securities litigation, calling him “a superstar.” Additionally, Benchmark Litigation: The Definitive Guide to America’s Leading Litigation Firms & Attorneys has recognized Brian as a “Future Star” and named him to its “Under 40 Hot List” three years in a row.

In 2019, Brian was honored with a Burton Award for Distinguished Legal Writing for his Review of Securities & Commodities Regulation article, “How Institutional Dynamics Have Shaped Insider Trading Law.” Brian is the co-author of “Insider Trading” and “Securities Fraud,” two chapters in the treatise White Collar Crime: Business and Regulatory Offenses. Brian is also a co-author of the chapter “Responding to Subpoenas and Other Regulatory Requests” in the book Defending Corporations and Individuals in Government Investigations. Brian has written articles for The Review of Securities and Commodities Regulation and Practical Law, and is a regular contributor to The Insider Blog on Forbes.com. Brian served on Law360’s 2018 white collar editorial advisory board. In addition, Brian is the chair of the Criminal Advocacy Committee of the New York City Bar Association.

Prior to joining the U.S. Attorney’s Office, Brian was a Law Clerk to the Honorable Amalya L. Kearse of the U.S. Court of Appeals for the Second Circuit, and the Honorable Jed S. Rakoff of the United States District Court for the Southern District of New York. Brian received his J.D. from Columbia Law School in 2004, where he was an Articles Editor of the Columbia Law Review, was named a James Kent Scholar each year, and was awarded the Paul R. Hays prize for civil procedure and the Charles Bathgate Beck prize for property law. He received his B.A. from Yale College in 2001, cum laude, with distinction in the English major.


Kan M. Nawaday is a seasoned trial, investigations, and criminal defense lawyer. A former Southern District of New York federal prosecutor, Kan zealously defends clients facing federal and state criminal and civil enforcement actions. He draws on his experience of having led more than 100 investigations, involving corruption and financial fraud; campaign finance fraud; bank, tax, and healthcare fraud; and money laundering.

Kan has tried 15 federal jury trials, and briefed and argued many federal appeals. National television news outlets often call upon Kan as a legal commentator – he has appeared on CNN, MSNBC, Bloomberg TV, and Vice News. Kan has also been quoted in newsprint publications, such as the New York Times. At Venable, Kan has conducted sensitive internal investigations, and has defended and advised clients in cases involving the federal and state False Claims Act, criminal antitrust, the Foreign Corrupt Practices Act, campaign finance fraud, art fraud, wire fraud, healthcare fraud, and sexual assault and harassment.

Government Experience

  • Assistant United States Attorney, U.S. Attorney's Office for the Southern District of New York – Nine Years (2009-2018)

Representative Matters

  • Defended a nonprofit organization against allegations of mishandling of a sexual harassment investigation, resulting in an appellate defense verdict before the Second Circuit Court of Appeals
  • Defended a multi-billion-dollar company in parallel state and federal False Claims Act investigations
  • Represented a private equity fund and directors of the fund’s portfolio company in connection with a DOJ healthcare fraud investigation of the portfolio company
  • Represented high-net worth individuals in connection with DOJ art fraud investigations

Education

  • J.D., magna cum laude, Cornell Law School, 2003
    • Editor-in-Chief, Cornell Law Review
  • M.A., French Language, Middlebury College, 2000
  • B.A., Comparative Literature, Yale University, 1996


Rebecca Ricigliano is an experienced trial and investigations lawyer, who served as a federal prosecutor in the Southern District of New York and as the second highest ranking executive at the New Jersey Attorney General's office. She conducts internal investigations for foreign and domestic clients and represents individuals and companies in grand jury and regulatory investigations, criminal trials, and civil enforcement actions. A member of Crowell & Moring’s White Collar & Regulatory Enforcement Group, Rebecca is resident in the firm’s New York office.

Prior to joining Crowell & Moring as a partner, Rebecca served as an Assistant United States Attorney in the Southern District of New York, where she held various supervisory positions including Chief of the Narcotics Unit and Senior Trial Counsel in the Public Corruption Unit. She was also a member of the Securities and Commodities Fraud Task Force. At SDNY, Rebecca first-chaired several jury trials and briefed and argued multiple cases before the U.S. Court of Appeals for the Second Circuit. She successfully tried a high-profile accounting and securities fraud case against the former CEO and CFO of a major drug store chain. 

Rebecca also led investigations and prosecutions of members and associates of foreign terrorist organizations for material support and hostage taking, and high-ranking cartel members for narcotics and money laundering offenses. Rebecca led the 2013 Medicaid fraud investigation and prosecution of 49 then-current and former Russian diplomats, and conducted an investigation of campaign financing violations related to a United States Senate race. Rebecca has been recognized by her colleagues for her efforts, receiving the Federal Drug Agents Foundation True American Hero Award and the Council of the Inspectors General on Integrity and Efficiency Investigations Award for Excellence.

Rebecca also served as the First Assistant Attorney General of New Jersey, where she supervised complex criminal investigations and prosecutions and affirmative Consumer Fraud and False Claims Act cases. She regularly provided strategic legal and policy counsel to the Attorney General and the Division of Consumer Affairs, the Division of Criminal Justice, and the New Jersey State Police. Prior to her government service, Rebecca was an associate at one of New York’s leading white collar criminal defense law firms, where she was a member of the defense team that represented Martha Stewart.


Simona Suh is an Assistant Regional Director in the Enforcement Division of the SEC and a member of the Division’s nationwide Market Abuse Unit.  She has been a key contributor to many SEC enforcement actions, including multiple insider trading cases, as well as cases involving market manipulation, unregistered securities offerings, misleading statements in dark pool operations, and other types of misconduct.  Before joining the SEC in 2004, Ms. Suh was in private practice in New York City and clerked for the Honorable Richard J. Cardamone of United States Court of Appeals for the Second Circuit and for the Honorable Carol B. Amon of the United States District Court for the Eastern District of New York.  Ms. Suh received her J.D., magna cum laude, from the Fordham University School of Law in 2001, and later taught legal writing at that law school.  She received her B.B.A. in Public Accounting, summa cum laude, from Pace University in 1998.


Jason Cowley has been with the United States Attorney’s Office for the Southern District of New York since 2011 and has served as Co-Chief of the Office’s Securities and Commodities Fraud Task Force since January 2017.  Prior to assuming that position, he served as Chief of the Office’s Money Laundering and Asset Forfeiture Unit.  Mr. Cowley has prosecuted a number of individuals and entities for a wide array of white-collar offenses including securities fraud, money laundering, violations of the Foreign Corrupt Practice Act (“FCPA”), tax evasion and related violations of the Bank Secrecy Act.  As a prosecutor, Mr. Cowley has tried over a dozen federal criminal jury trials.