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The Foreign Corrupt Practices Act and International Anti-Corruption Developments 2020


Speaker(s): Adam Wolf, Aisling O'Shea, Alixandra Smith, Allen W. Chiu, Andrew Stemmer, Audrey L. Harris, Catherine Razzano, Charles E. Cain, Christopher Cestaro, Colette Devine, Damali Taylor, Eric Rahn, Geoffrey A. David, James Walker, Jay Holtmeier, Joan Meyer, Julia C. Symon, Kara Novaco Brockmeyer, Karla Maeji, Kathryn Cameron Atkinson, Kevin Abikoff, Kimberly A. Parker, Kristin Graham Koehler, Lucinda A. Low, Margaret C. Mousoudakis, María González Calvet, Martine M. Beamon, Nancy F. Lanis, Palmina M. Fava, Patricia M. Byrne, Patrick F. Stokes, Peter Jaffe, Richard S. Levick, Esq. , Richard W. Grime, Robert Dodge, Rogeria Gieremek, Rohan A. Virginkar, Ryan Donohue, Sandra L. Moser, Sharie A. Brown, Tarek J. Helou, Thomas J. Koffer, William B. Jacobson
Recorded on: Sep. 3, 2020
PLI Program #: 276892

Adam Wolf is the Head of Global Anti-Bribery and Corruption (ABC) Advisory for MUFG Bank. 

Adam helped to design and implement MUFG’s global ABC policy and procedures applicable to more than 40 offices and 100,000 employees worldwide, and he provides guidance and strategic advice on a wide range of issues and business transactions.

Before he joined MUFG in 2016, Adam practiced law for more than ten years at two large international law firms, where he counseled major financial institutions and other multinationals on their ABC compliance programs, managed global bribery investigations, and conducted a three-year FCPA compliance monitorship.

Adam graduated with honors from Brooklyn Law School in 2005, where he was an editor of the Law Review, and received his Bachelor of Arts from Brown University.  Prior to attending law school, Adam worked as a legislative assistant on Capitol Hill in Washington, D.C. and at an internet start-up company in San Francisco.

Adam has published numerous articles regarding ABC issues and developments.


Alixandra Smith is the Chief of the Business and Securities Fraud Section at the United States Attorney’s Office for the Eastern District of New York (“EDNY”).  She has investigated and prosecuted a wide variety of criminal matters against both individuals and entities, including fraud involving publicly-traded companies, market manipulation, insider trading, healthcare fraud, tax crimes, money laundering, cyber-enabled crime and violations of the Foreign Corrupt Practices Act (“FCPA”).  Alix is also an adjunct professor at New York University Law School.

During her time at the Office, Alix has worked on significant white collar cases.  For example, Alix was the co-lead prosecutor on the case United States v. Martin Shkreli and Evan Greebel, in which a pharmaceutical executive and his attorney were charged with securities fraud, wire fraud conspiracy and securities fraud conspiracy in connection with four complex fraud schemes.  Both defendants were tried and convicted in separate trials lasting a combined total of 17 weeks in 2017.  In addition, Alix led the Office’s team that, along with the Department of Justice’s Fraud Section, investigated and prosecuted United States v. Odebrecht and United States v. Braskem, collectively one of the largest foreign bribery cases in history.  In that case, Brazilian-based companies Odebrecht and Braskem pled guilty to conspiracy to violate the FCPA for their roles in a bribery scheme that involved payments of close to a billion dollars over a 15-year period to foreign government officials in Brazil and twelve other countries to obtain and retain business in those countries.  Alix was also the lead criminal prosecutor for United States v. AmerisourceBergen Specialty Group, in which a subsidiary of a major pharmaceutical company pled guilty to a violation of the Federal Food, Drug and Cosmetics Act for the illegal distribution of misbranded oncology drugs, and paid a total of $885 million in criminal and civil penalties. 

Prior to joining the Office, Alix was an associate at two law firms in New York; completed clerkships with the Honorable Julio M. Fuentes, United States Court of Appeals for the Third Circuit, and the Honorable Faith S. Hochberg, United States District Court for the District of New Jersey; and served as an adjunct professor at Fordham Law School.  She graduated from Harvard University and Harvard Law School.

 

 

 


Allen W. Chiu is Senior Vice President, Chief Compliance Officer and Associate General Counsel, Litigation for Genesys.  In that role, Allen is responsible for the end-to-end management of Genesys’ ethics and compliance program, which includes overseeing its global anti-corruption/anti-bribery and trade compliance programs, as well as its litigation docket worldwide. 

Before joining Genesys, Allen was an Assistant United States Attorney with the U.S. Department of Justice, where he served in the National Security and Criminal Divisions of the U.S. Attorney’s Office for the Central District of California.  In March 2016, Allen was selected by the Daily Journal and California Lawyer magazine to receive the California Lawyer of the Year Award in the National Security category.  Prior to becoming a federal prosecutor, Allen was an Associate with Latham & Watkins LLP. 

Allen is a graduate of the UCLA School of Law, where he served as a Managing Editor of the UCLA Law Review.


Audrey Harris rejoined Mayer Brown in Washington DC as a partner and co-chair of its Global Anti-Corruption & FCPA practice after serving as the chief compliance officer (CCO) for global resources company BHP. Based in Melbourne, Australia, she led a global ethics & compliance function providing expertise in anti-corruption, trade sanctions, export controls, competition, ethics & investigations, state & commercial secrets, and market conduct compliance, with a team of professionals and attorneys across four continents.

Audrey served as the company's first chief compliance officer. Her team was accountable for safeguarding integrity by preventing, mitigating, and investigating compliance risks and setting ethical standards. Her role also involved work with NGOs, international governing bodies and enforcement agencies as part of the promotion of global anti-corruption, transparency and integrity.

A veteran Foreign Corruption Practices Act (FCPA) and white collar practitioner, prior to becoming a CCO, Audrey was a partner at Mayer Brown with more than a decade of experience handling multi-year, multinational investigations, with a comprehensive investigations, counseling and defense capability.

Audrey regularly appears before enforcement authorities and has extensive experience in designing, executing and presenting internal investigations before multinational corporations, the US Department of Justice (DOJ), Securities & Exchange Commission (SEC), Department of Treasury Office of Foreign Assets Control (OFAC), Department of Defense, and Multilateral Development Banks (MBDs). Her experience runs the gamut of white collar representations including false claims act, healthcare fraud, management of earnings, money laundering defense, and even anti-terrorism matters. Before joining Mayer Brown, Audrey was a partner at another leading global law firm.


Christopher Cestaro is the Chief of the Foreign Corrupt Practices Act (FCPA) Unit within the U.S. Department of Justice, Criminal Division, Fraud Section, which is responsible for all FCPA investigations and prosecutions initiated and charged by the Department.  Between January 2017 and July 2019, Chris served as an Assistant Chief in the FCPA Unit, and Chris served as a trial attorney in the FCPA Unit from 2014 through January 2017.  Prior to joining the FCPA Unit, Chris worked as a Trial Attorney in the Fraud Section’s Health Care Fraud Unit, where he prosecuted Medicare fraud cases.  Before becoming a prosecutor, Chris worked at an international law firm and as a compliance counsel at a multinational corporation.  Chris graduated from the University of Richmond and the University of Virginia School of Law.


Colette Devine is the Deputy Chief Compliance Officer at The AES Corporation, a Fortune 500 global power company.  Colette leads AES’ global anti-corruption program and is responsible for developing and overseeing the AES third party management program and global FCPA program.  Prior to joining AES in 2003, Colette was an attorney with Hogan & Hartson, where she specialized in corporate and securities transactions.  Prior to attending law school, Colette was the Program Officer for Northeast Asia at The Asia Society in New York City. 

Colette received her Juris Doctor from the University of Virginia School of Law, a Master of Arts in East Asian Studies from Harvard University, and a B.A. from Georgetown University. 


Eric J. Rahn is Associate General Counsel at Booz Allen Hamilton, where he serves as the legal and compliance lead of Booz Allen’s anticorruption program.

Eric graduated cum laude from the Georgetown University Law Center in 2007. Before joining Booz Allen in 2017, he worked on investigations and compliance counselling in the DC offices of two large international law firms. While working for those firms, he also spent over a year seconded to the Ethics & Compliance team of a major Silicon Valley-based technology company.


Geoffrey David is Group Head, Litigation & Investigations at Rio Tinto overseeing its litigation, disputes and investigations around the globe.  He spent over 13 years in private practice defending corporate clients from a variety of industries in a wide range of litigation and investigations.  Geoff has a BS in Chemistry from The College of William and Mary and a JD from The George Washington University Law School. 


Jay Holtmeier is a partner in Wilmer Cutler Pickering Hale and Dorr LLP’s Litigation/Controversy Department, and a member of the Investigations and Criminal Litigation Practice Group. He co-leads the firm's Foreign Corrupt Practices Act and Anti-Corruption Group. He joined the firm in 2004.

Mr. Holtmeier's breadth of experience as a litigator includes service as a federal prosecutor, a senior in-house attorney and a lawyer in private practice. Mr. Holtmeier represents institutions and individuals in complex government and internal investigations and matters of corporate governance and compliance. He has particular expertise in matters involving the Foreign Corrupt Practices Act (FCPA).

In FCPA matters, Mr. Holtmeier has represented clients in government and internal investigations involving conduct in Europe, Asia, the Middle East, Africa, Latin America and Australia. He regularly counsels clients facing difficult FCPA issues in a variety of business contexts, and he has assisted clients in numerous industries in developing and implementing FCPA compliance programs. He devotes substantial attention to advising clients on FCPA problems that arise in the context of mergers and acquisitions, joint ventures and other corporate transactions. He writes and speaks extensively on the subject and is a co-author, with partners Roger Witten, Kimberly Parker, and Erin Sloane, of the leading treatise in the field, Complying with the Foreign Corrupt Practices Act (9th ed. 2016).

As a senior vice president and principal legal counsel with the Reuters Group, Mr. Holtmeier was responsible for all litigation and compliance matters in North and South America. As an assistant US Attorney for the Southern District of New York, he tried several cases to verdict and led extensive grand jury investigations of various crimes, including racketeering, securities fraud, murder, narcotics and counterfeiting. Significant prosecutions included United States v. Jose Muyet, et al., and United States v. Ronald Ocasio, et al., related cases involving more than twenty murders, for which Mr. Holtmeier received the Director's Award for Superior Performance from the Executive Office for US Attorneys, and United States v. Carol Bayless, which received national attention and calls for the impeachment of the presiding US District Judge.

 


Joan Meyer is a partner in the Firm's Washington, DC office. She has handled investigations and resolutions with enforcement authorities involving anti-corruption, securities violations, government contracting and the False Claims Act, and financial frauds for domestic and international companies. Prior to joining the Firm, she was senior counsel to the Deputy Attorney General at the US Department of Justice, where she advised on corporate charging policies, corporate monitorships, and complex criminal litigation and corporate settlements. She also managed the operation of the President's Corporate Fraud Task Force. Joan was the First Assistant United States Attorney and Criminal Chief of the United States Attorney's Office in the Western District of Michigan.

While working as a federal prosecutor, Joan was a recipient of two national awards for her successful prosecutions. She also specialized in civil financial fraud as a senior trial attorney at the Commodity Futures Trading Commission in Washington, DC where she filed federal injunctive and administrative actions against brokerage firms and individual brokers for a variety of solicitation and trading frauds connected to the commodity futures markets. She started her career as a criminal prosecutor in Chicago. Joan is an experienced trial lawyer and has argued many appeals in state and federal courts.

Joan counsels on best practices for compliance with US and international legal requirements and regulations, advises senior management and corporate audit committees on the formulation, conduct, and consequences of enforcement inquiries, including the development of appropriate defenses, disclosures, disciplinary actions and compliance policies. Joan has done extensive work across the globe, with many notable cases from Latin America and advises internal investigations for international companies doing business in Latin America. She has advised and worked with companies in the manufacturing, life sciences, mining and extraction, financial services, transportation and logistics sectors to conduct domestic and global risk assessments, develop and implement compliance programs, create remediation plans and develop emergency/crisis management strategies.  Joan was part of a team that received an award from the Latin Lawyer for one of her cases. She recently co-authored “Corporate Settlement Tools, Deferred Prosecution Agreements, Non-Prosecution Agreements and Cooperation Agreements, published by Bloomberg Law in 2018.


Julia Symon is a Vice President and the Chief Compliance Officer at KBR, Inc., and is responsible for KBR’s ethics, trade and anti-corruption compliance programs.  

Julia was instrumental in the successful completion of KBR’s three-year relationship with the Company’s corporate monitor who was appointed after KBR’s guilty plea and related settlement with the DOJ and SEC in February 2009.

Prior to joining KBR in 2009, Julia was Counsel at Clifford Chance in Washington DC and represented clients in regulatory, compliance and litigation matters.


Karla Maeji is a partner in the Compliance & Investigation practice at TozziniFreire with extensive experience acting as counsel for foreign listed companies doing business in Brazil, focusing her practice on internal investigations and regulatory and criminal enforcement.

She graduated from the Law School of Universidade Presbiteriana Mackenzie in 2008 and holds an LL.M from the Law School of Columbia University School of Law, New York, NY, USA, in 2013.

Karla conducted numerous cross-border investigations especially on corruption, fraud and procurement irregularities reporting to Audit Committees, interacting with external auditors and having a keen eye for handling matters that may impact the company in different areas of law and jurisdictions. She has consistent experience strategically representing clients before multiple authorities, both in the context of leniency agreements and defense. 

Karla also regularly advises corporate clients on a broad range of compliance matters for having a deep understanding of her clients’ business and potential impacts for the company.

 


Kathryn Cameron Atkinson is the Chair of Miller & Chevalier. She has twice been selected as a government-appointed Independent Compliance Monitor. She currently serves as a Department of Justice/Securities and Exchange Commission (DOJ/SEC)-appointed Monitor pursuant to a Foreign Corrupt Practices Act (FCPA) deferred prosecution agreement (DPA). She previously served as Monitor for KBR, Inc. in an FCPA matter settled with the DOJ and SEC. 

Ms. Atkinson has served as faculty in the CEELI Institute’s Investigating and Prosecuting Official Corruption training for foreign prosecutors. She was named to Global Investigation Review's "Women in Investigations 2015," Latinvex's "Latin America's Top 100 Female Lawyers: FCPA and Fraud" (2017), and the Ethisphere Institute's "Attorneys Who Matter" list (2015, 2017). "The 'extremely knowledgeable and experienced' Kathryn Cameron Atkinson 'brings a great approach to difficult situations,'" notes Chambers USA and Chambers Global, where she is ranked Band 2 in FCPA (Nationwide).


Kevin T. Abikoff is the Deputy Chair of Hughes Hubbard & Reed LLP.  He is Co-Chairman of the firm’s Anti-Corruption & Internal Investigations, Securities Litigation and Class Actions practice groups, and a member of the firm’s Executive Committee. Kevin regularly advises clients across myriad industries and geographic regions on the full range of anti-corruption issues. He was appointed as the independent compliance monitor for Innospec by the U.K. Serious Fraud Office, U.S. Department of Justice, and U.S. Securities & Exchange Commission (and with approval from U.S. Office of Foreign Assets Control). Kevin also led the engagement for a multinational oilfield services company in its post-DPA activities and served as an independent compliance monitor appointed by the United Nations. Currently, he serves as the independent compliance monitor for a Chinese state-owned construction enterprise in connection with a debarment and sanction by the World Bank.

Kevin leads the firm’s engagements for several multinational companies subject to investigations and in their post-resolution activities, and has successfully assisted numerous multinational companies in satisfying terms of negotiated settlements with international regulators. Kevin currently represents a world-leading aerospace and defense company in connection with anti-corruption reviews and related multi-jurisdictional investigations. Kevin also leads the firm’s engagements relating to enforcement activity by multilateral development banks, such as the World Bank, the Asian Development Bank and the African Development Bank.

Kevin is the author of Corporate Governance: Avoiding and Responding to Misconduct (Law Journal-Seminars Press 2007) (updated semi-annually thereafter), which includes chapters on anti-corruption and white-collar criminal issues, and co-author of Anti-Corruption Law and Compliance: Guide to the FCPA and Beyond (Bloomberg BNA 2014). Immediately prior to joining Hughes Hubbard, he was Senior Vice President and General Counsel of Corporate and Compliance for American General Corporation, a $23 billion company. In this role, he developed the company’s compliance infrastructure, policies, and procedures, and he had direct responsibility for the company’s entire compliance environment.


KRISTIN KOEHLER, a member of the firm’s Executive Committee, has handled numerous United States Department of Justice (DOJ) criminal investigations involving public corruption, procurement fraud, healthcare fraud, antitrust, securities fraud and violations of the Foreign Corrupt Practices Act (FCPA). She also has significant experience representing clients in DOJ civil qui tam investigations, State AG investigations and congressional investigations. Kristin routinely conducts sensitive internal investigations on behalf of corporations and individuals. She also regularly counsels clients on the creation, enhancement and implementation of compliance programs.

Kristin has been recognized for several years in Chambers USA: America’s Leading Lawyers for Business, White-Collar Crime and Government Investigations Litigation.  She also is recognized in the 2019 edition of The Best Lawyers in America as a leading litigator in white-collar criminal defense, and has been recognized every year since 2013. She has also been named one of the “Top 250 Women in Litigation” (2017–2019) and a “Local Litigation Star” in Washington, D.C. (2015–2017) by Benchmark Litigation. Washingtonian magazine has included Kristin in its current roster of 2019 “Washington, D.C.’s Best Lawyers” for Criminal Defense — White Collar. Kristin also has been acknowledged by The Legal 500 (2013) for her white collar criminal defense work and was named by Washington DC Super Lawyers as one of the capital region’s “Top 50 Women” lawyers (2014 & 2015) and a top lawyer in 2017. The Corporate Crime Reporter also recognized Kristin as one of the top 150 Women in White Collar (2016).

Prior to joining Sidley, Kristin served as a law clerk to the Honorable David G. Larimer, Chief Judge of the U.S. District Court for the Western District of New York. She graduated with honors from the State University of New York, where she was the assistant executive editor of the Law Review and a member of the National Trial Advocacy Team. While at the State University, Kristin was the recipient of the Justice Phillip Halpern Award for Excellence in Writing on the Law Review and the Law Faculty Award for Outstanding Contributions to the Law School.


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, and serves on the firm’s Executive Committee. Her practice focuses on the U.S. Foreign Corrupt Practices Act and other anti-corruption laws, as well as other international regulatory compliance issues for multinational businesses, as well as multijurisdictional regulatory and enforcement matters. Ms. Low has extensive experience in internal and government investigations, representing companies, Audit Committees and Board of Directors, and individuals in enforcement matters before the U.S. Department of Justice, Securities and Exchange Commission, and the World Bank and other international financial institutions and foreign authorities. Ms. Low's practice also includes compliance counseling and advice, representation in disputes between commercial parties and host governments, including disputes involving issues of fraud and corruption.  She has received a Band 1 Ranking in both Chambers Global and USA legal directories for International Trade: FCPA Experts for the past ten years (2010-2019). Ms. Low has also been listed in Best Lawyers in America from 2001-2020 for International Arbitration: Governmental and International Trade and Finance Law, and in Super Lawyers Washington, DC, International from 2013-2019. In 2019, she was also listed in Super Lawyers’ list of “Top 50 Women.”

Ms. Low is the Immediate Past President of the American Society of International Law, the Vice Chair of the Board of Directors of the Coalition for Integrity (formerly known as Transparency International-USA) and serves on its Executive Committee, and was the first woman to chair the ABA Section of International Law.  She has received numerous awards for her work. Most recently, she received the Louis B. Sohn Award for Public International Law from the ABA Section of International Law.  In 2017, she received the Outstanding Career award from the Global Investigations Review, which in 2015 also named her to its list of “Women in Investigations: One Hundred Investigation Specialists from Around the World.” 

Ms. Low was appointed in 2017 by the President of the World Bank to the Panel of Arbitrators of the International Centre for Settlement of Investment Disputes (ICSID); and in 2016 was appointed by President Obama to the ICSID Panel of Conciliators.  She currently sits as President of two ICSID arbitration tribunals and is a member of an annulment committee in a third case.  She also serves on the U.S. Secretary of State’s Advisory Committee on Public International Law.  She also has significant experience as counsel in investor-state and commercial arbitration proceedings, and as an expert witness in disputes raising bribery and corruption and related issues.

Ms. Low was Editor-in-Chief of the UCLA Law Review in 1976-77.  I addition to her J.D. from UCLA Law School, she holds a B.A. from Pomona College, where she designed an inter-disciplinary major in Latin American Studies and Economics.  Ms. Low speaks Portuguese, Spanish and French, and has some knowledge of Russian, Italian and Japanese.


María González Calvet is an anti-corruption and international risk partner in the firm’s Washington, D.C. office. Recognized for her deep understanding and experience in the application of the Foreign Corrupt Practices Act and other anti-bribery statutes in Latin America, she has worked with leaders in government, business and finance to investigate and assess risk across the region for more than a decade. She has substantial experience conducting investigations on behalf of companies and individuals concerning multi-jurisdictional matters involving corruption, money laundering, and other forms of financial fraud.

María has conducted internal and government investigations in more than 20 Latin American countries and draws on her past work in government and the corporate sector to help clients across industries and geographies to identify and mitigate corruption risks and implement effective compliance programs. In addition to her Latin America knowledge, María has experience in anti-corruption and other investigative matters in Asia, Africa, and Europe, and in every significant business sector.

She has particular experience in the following areas:

  • Jurisdictional questions and challenges that arise from coordinated prosecution by multiple enforcement authorities
  • Transactions and business dealings with government entities and financial institutions
  • Risks associated with consortia and other partnerships
  • Pre- and post-acquisition due diligence in high-risk markets

Prior to joining Ropes & Gray in 2018, María served as Executive Counsel, Global Investigations for General Electric where she led and managed government, regulatory and internal investigations for the company’s business in Latin America. Earlier in her career, she was a trial attorney in the U.S. Department of Justice’s Criminal Division, Fraud Section, and was a member of the Foreign Corrupt Practices Act Unit where she led some of the Department’s most important investigations involving allegations of corruption and other white collar offenses in Latin America. María is a fluent, native Spanish speaker, and an advanced Portuguese speaker. Before becoming a lawyer, she worked in education, focusing on adult literacy and bilingual education.


Margaret C. Mousoudakis is Assistant Compliance Officer for LyondellBasell, one of the world’s largest olefins, polyolefins, chemicals and refining companies. She is based in Houston, Texas. 

Margaret joined LyondellBasell in April 2010 to assist the company in establishing a Compliance department which included implementing a new Code of Conduct, new company wide policies and procedures including an Anti-Corruption Policy, Gifts, Entertainment, and Travel Policy and Due Diligence Procedures for Third Parties.  Currently, Margaret’s practice focuses on Trade Compliance including issues involving sanctioned countries and other trade related issues.   Margaret is also a regular speaker and commentator at compliance conferences.

Prior to joining LyondellBasell, Margaret was most recently a Senior Attorney at Marathon Oil Company where her practice included providing Foreign Corrupt Practices Act legal support to all Marathon subsidiaries.  Prior to joining Marathon Oil Company, she was in private law practice focusing on the litigation and arbitration of complex commercial disputes at Doyle, Restrepo, Harvin & Robbins, L.L.P.

Margaret received a Bachelor of Arts degree in History and Spanish from Washington and Lee University in 1996, graduating cum laude.  She obtained a juris doctor degree from South Texas College of Law in 1999, where she served as assistant managing editor of the South Texas Law Review. 


Nancy Lanis leads the Compliance Team for Henry Schein, Inc., a Fortune 500 company and the largest provider of health care solutions to office-based dental and medical practitioners globally.  Nancy’s responsibilities include compliance program design, oversight and implementation, and advising  Board of Director and Senior Management Committees, as well as and others throughout the Company on ethics and compliance matters. 

Prior to joining Henry Schein, Nancy served as General Counsel of Curative Health Services, a NASDAQ public company specializing in wound care and specialty pharmacy services to chronic care patients; General Counsel, Infusion and Biotech for Olsten Kimberly QualityCare, then the largest national home health care provider; Corporate Counsel for W.R.Grace & Co., a Fortune 500 specialty chemical conglomerate, and as a Corporate Associate for Cole & Dietz (now Winston & Strawn). She has also worked for the N.Y State Attorney General’s Office and United Nations Centre for Transnational Corporations. 

Nancy speaks periodically as a panelist and presenter in various industry forums. 

Nancy is a graduate of Yale College (B.A., magna cum laude) and New York University Law School (J.D., 1983), and is a member of the New York State Bar.


Palmina Fava is a partner in the New York office of Vinson & Elkins, LLP, specializing in internal and government investigations, white collar criminal defense, and corporate governance counseling.

Palmina regularly represents companies in matters before the United States Department of Justice (DOJ), the Securities and Exchange Commission (SEC), other federal and state agencies, and international regulatory bodies related to the Foreign Corrupt Practices Act (FCPA), international anti-corruption, anti-money laundering and anti-bribery laws, accounting irregularities, bid rigging and unfair trade practices, off-label pharmaceutical marketing, misappropriation of trade secrets, fraud, cybersecurity, and data privacy.

Additionally, Palmina designs and implements practical and comprehensive compliance programs and internal controls tailored to a company’s particular risk profile.  She also conducts third party and M&A due diligence, develops and provides training, and drafts compliance reps and warranties.

Palmina graduated cum laude from Georgetown University in 1994 and received her J.D. with honors from Fordham University School of Law in 1997. She is President of the Fordham Law Alumni Association and a board member of the Kidney & Urology Foundation of America and of New Classrooms. 

Palmina is fluent in Italian and proficient in Spanish and Portuguese.


Patrick F. Stokes is a litigation partner in Gibson, Dunn & Crutcher's Washington, D.C. office. He is a member of the firm's White Collar Defense and Investigations, Securities Enforcement, and Litigation Practice Groups.

Mr. Stokes' practice focuses on internal corporate investigations, compliance reviews, government investigations, and enforcement actions regarding corruption, securities fraud, and financial institutions fraud. He has tried more than 30 federal jury trials as first chair, including high-profile white-collar cases, and handled 16 appeals before the U.S. Court of Appeals for the Fourth Circuit. Mr. Stokes is equally comfortable leading confidential internal investigations, negotiating with government enforcement authorities, or advocating in court proceedings.

Prior to joining Gibson Dunn, Mr. Stokes spent nearly 18 years with the U.S. Department of Justice (DOJ). From 2014 to 2016 he headed the FCPA Unit, managing the DOJ's FCPA enforcement program and all criminal FCPA matters throughout the United States, covering every significant business sector, and including investigations, trials, and the assessment of corporate anti-corruption compliance programs and monitorships. Mr. Stokes also served as the DOJ's principal representative at the OECD Working Group on Bribery working with law enforcement and policy setters from 41 signatory countries on anti-corruption enforcement policy issues.

From 2010 to 2014, he served as Co-Chief of the DOJ's Securities and Financial Fraud Unit. In this role, he oversaw investigations and prosecutions of financial fraud schemes involving accounting fraud, benchmark interest rate manipulations, insider trading, market manipulation, Troubled Asset Relief Program (TARP) fraud, government procurement fraud, and large-scale mortgage fraud, among others.

From 2002 to 2008, Mr. Stokes served as an Assistant United States Attorney in the Eastern District of Virginia, where he prosecuted a wide variety of financial fraud, immigration, and violent crime cases. From 1998 to 2002, he served in the DOJ's Tax Division as a trial attorney in the Western Criminal Enforcement Section.

Mr. Stokes received various awards while at the DOJ, including the Attorney General's Distinguished Service Award in 2013 and 2014 and the Assistant Attorney General's Exceptional Service Award (Criminal Division) in 2011 and 2014.

Mr. Stokes received his bachelor's degree and Juris Doctor from the University of Virginia, where he was an editorial board member of the Virginia Journal of Social Policy and the Law.

Mr. Stokes is admitted to practice in the District of Columbia, the District of Maryland, the Eastern District of Virginia, the Western District of Washington, and the Fourth Circuit.


Peter Jaffe is counsel in the firm’s Washington, D.C. office and serves as the Deputy Chair of the Anti-Corruption & FCPA Practice Group. He focuses on counseling, compliance program design and implementation, M&A and transactional due diligence, Foreign Corrupt Practices Act and corruption-related internal investigations and corporate governance issues.

Peter previously served as Chief Ethics and Compliance Officer of The AES Corporation, where he managed the company's global ethics and compliance program, designed and implemented corporate compliance polices, oversaw internal investigations and conducted due diligence on major M&A transactions and foreign investments in high-risk countries.

Peter has advised numerous leading multinational corporations on the design and implementation of corporate compliance and training programs, and the financial controls related to such programs, with an international emphasis. He has represented clients before the United States Department of Justice, the Securities and Exchange Commission and other U.S. and non-U.S. regulatory agencies. Peter has significant expertise in anti-corruption laws, including the FCPA and U.K. Bribery Act, securities and accounting matters, officers and directors liability, corporate governance, financial fraud and other regulatory issues. He also has comprehensive experience conducting complex internal and independent investigations for corporations and audit committees.

Earlier in his career, Peter was President and Chief Legal Officer of a multimillion dollar technology and services company. He worked as a trial attorney at the United States Department of Justice, where he was assigned to serve as special assistant in the United States Attorney's Office for the Eastern District of Virginia. During his tenure at the Department of Justice, Peter also served as counsel to the United States Senate Judiciary Committee, where he advised the United States Senate on constitutional law and domestic and international criminal issues.

Peter frequently speaks on FCPA and other ethics and compliance issues. He has been recognized by Ethisphere Magazine as one of the top ethics and compliance officers of major companies and included on its list of "Attorneys Who Matter in Ethics and Compliance." Peter is a member of the Board of Directors of the Ethics Research Center and the Ethics and Compliance Association, where he was the founding chairman of its Global Business Interest Group.

Peter graduated from Michigan Law School where he was notes and associate editor of the Michigan Law Review and was elected to the Order of the Coif.


Richard Levick, Esq. is Chairman & CEO of LEVICK, representing countries and companies in the highest-stakes global communications matters – the Venezuelan crisis; Qatar; the Chinese trade war; the Gulf oil spill; Guantanamo Bay, the Catholic Church and many others.

Mr. Levick was honored multiple times on the prestigious list of “The 100 Most Influential People in the Boardroom” and has been named to multiple professional Halls of Fame for lifetime achievement.

He is the co-author of four books and is a regular commentator on television and in print. Mr. Levick speaks all over the world; at West Point, The Army War College and teaches at Fordham Law School.


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. 

Richard’s practice focuses on representing companies and individuals facing government investigations relating to corruption, accounting fraud, and securities fraud.  Richard also advises on compliance and corporate governance matters.

Richard spent over nine years in the Division of Enforcement at the Securities and Exchange Commission in Washington, DC. handling a full range of enforcement matters relating to FCPA, insider trading, and accounting fraud.

Richard is consistently ranked highly by Chambers USA for FCPA and white collar work.


Robert I. Dodge is an Assistant Director in the Securities and Exchange Commission’s FCPA Unit in Washington, DC.  Bob has been at the Commission for sixteen years. 

Prior to his current position, he served as Assistant Chief Litigation Counsel, focusing primarily on FCPA enforcement actions.  In that role, Bob was lead trial counsel in the SEC v. Straub and SEC v. Sharef cases. 

Before  joining the SEC, Bob held several positions at the Department of Justice, including as an Assistant U.S. Attorney and Assistant Section Chief in the Environmental Defense Section. 

He graduated from Columbia Law School in 1987.


Rogeria P. B. R. Gieremek, CCEP, has 33 years of experience in the legal field, with the last 8 years working exclusively to the Compliance area. She graduated in law in 1987, at the Sao Bernardo do Campo Law School and achieved a PHD in Administrative Law in 2001 at PUC / Sao Paulo. Rogeria worked as a lawyer at Banespa S / A in the Contract area and chaired the Bid Committee for 4 periods.

Rogeria served for 14 years at Serasa S / A, and until Oct / 2014 was responsible for compliance in Latin America (Brazil, Argentina, Mexico, Colombia, Peru and Venezuela), having structured the area in the region. Before that, Rogeria served as Legal Executive Manager in the same company, gaining experience in M & A, IPO and JV projects, including their submission to CADE, as well as guidance and overseeing of all relevant papers to the drafting of contracts, operational and non-operational and the issuance of legal opinions on the various branches of law. Rogeria was also responsible for the risk management process until May / 2012.

In Oct / 2014, Rogeria became Global Consultant of the Compliance Program, assisting directly the Experian Global Compliance Vice-President in implementing the Global Program of Compliance, with special focus on Latin America, the United Kingdom / Ireland and Europe / Middle East and Africa, a position that she hold until Aug / 2015.

In Aug / 2015, she started working at LATAM Airlines Group (Association between TAM and LAN airlines), as Chief Compliance Officer of the Group, globally responsible for the implementation of policies and procedures, internal investigations, training, opinions and due diligence, among other matters, worth highlighting the process for hiring TPIs (Third Party Intermediaries), globally.

She introduced the Compliance Program based on the 7 Elements of Compliance, created and implemented the Compliance Ambassadors Program, participates in various Committees, including Compliance, Management of the Code of Conduct, IT, Contingencies and Risk Management. ROGÉRIA reports directly to the LATAM Global Board and to the Global Vice President of Legal Affairs and Compliance.

Rogeria is fluent in English and Spanish and had instrumental course of French at PUC / SP. She chairs the Compliance Committee of OAB / SP (Sao Paulo Bar Association), nominated in 2019, and also chairs the Compliance Committee of IASP, since 2013, having received the title of CCEP - Corporate Compliance and Ethics Professional by SCCE, in 2011.

She is one of the founders of Legal Skirts, a member of the Alliance for Integrity Advisory Board, a Compliance Women Committee Ambassador and a member of the WWCDA - Women White Color Defense Association (Chapter Brazil), having recently completed the 6th Advanced Compliance Workshop at the New York State BAR Association - International Section.

Rogeria is a speaker (in Portuguese, English and Spanish), in conferences, seminars and trainings on Law and Compliance, talking about compliance program and compliance policies, Brazilian Anticorruption Law (Law 12.846713), among other topics.


Ryan J. Donohue is an Executive Director in the Legal and Compliance Division at Morgan Stanley.  Ryan serves as in-house counsel and COO of the Firm’s Global Financial Crimes Legal group, specializing in delivering advice and counsel to the Firm’s businesses concerning anti-corruption, anti-money laundering, and economic sanctions issues.  Ryan also coordinates the Firm’s Global and Americas reputational risk committees. 

Ryan is a graduate of New York University and the Emory University School of Law.  After graduation from law school, Ryan was an attorney in the litigation departments of Dickstein Shapiro (now d/b/a Blank Rome) and Akin Gump Strauss Hauer & Feld, specializing in complex commercial litigation, securities litigation, and white collar criminal defense, before joining Morgan Stanley in 2015.


Sandra Moser is a Partner in the Washington, D.C. and Philadelphia offices of Morgan Lewis. Ms. Moser’s practice focuses on the representation of companies, boards of directors and senior executives in investigations, sensitive matters, corporate crises, litigation and other disputes involving law enforcement and regulatory agencies around the world.

Ms. Moser is the former chief of the Department of Justice (DOJ) Fraud Section in Washington, D.C., which has exclusive criminal enforcement jurisdiction over the DOJ’s enforcement of the Foreign Corrupt Practices Act (FCPA) and routinely handles many of the world’s most significant economic crime cases, including securities and commodities fraud, manipulation of financial markets, False Claims Act and other healthcare-related violations, and international money laundering offenses. Ms. Moser is an experienced trial lawyer who, prior to assuming the chief role, served the Fraud Section in several other leadership positions and also was for several years a federal prosecutor in the District of New Jersey’s elite Special Prosecutions Division. Prior to joining the Department of Justice, Ms. Moser worked in private practice and served as a federal law clerk for the U.S. District Court for the Eastern District of Pennsylvania and the U.S. Court of Appeals for the Third Circuit.

Ms. Moser earned her law degree at the Northwestern University Pritzker School of Law, where she graduated cum laude and served as editor for the Journal of Criminal Law & Criminology. She earned her undergraduate degree at the University of North Carolina at Chapel Hill, where she was awarded two degrees, in Journalism and Women’s Studies, and graduated first in her class.


Tarek Helou is a partner in the Washington, D.C., office of Wilson Sonsini Goodrich & Rosati, where he represents companies in internal investigations and defends companies and individuals in multi-jurisdictional government enforcement actions. He also handles crisis management and counsels clients on risk assessments, compliance, and due diligence, with a focus on anti-corruption matters. Tarek, a former supervisor in the U.S. Department of Justice’s FCPA Unit, has deep expertise in all aspects of government investigations, having led or supervised more than 100 FCPA investigations focusing on every major industry, including companies in the technology, software, data analytics, medical device, pharmaceutical, mining, oil and gas, and finance sectors. Tarek, a frequent speaker on anti-corruption issues, was in the DOJ’s FCPA Unit from 2012 to 2019.  Before that, he was an Assistant U.S. Attorney in San Francisco from 2007 to 2012, where he tried several cases and investigated and prosecuted cases involving drug trafficking, gangs, violent crime, and child exploitation. He worked at another law firm before that. He graduated from New York University School of Law in 2001 and Johns Hopkins University in 1996.


William Jacobson focuses his practice on FCPA and white collar enforcement, representing corporates, individuals, and financial institutions. Billy has over 25 years of experience, having served as the Chief Compliance Officer and Co-General Counsel of a global oilfield services company, as a federal prosecutor -- including as Assistant Chief for FCPA Enforcement in DOJ’s Fraud Section, and in private practice. Billy’s expertise both in corporate compliance and corporate criminal defense is a rare combination that serves clients well.


I've been doing compliance work for the better part of my career—nearly 20 years—and I still find it to be as fun and exciting as when I started. I'm a lawyer by trade, but compliance offers a very different path than traditional legal practice. Instead of engaging in disputes, compliance professionals get to be more proactive. I love that I get to partner with the business in order to provide protection, guidance, and true leadership.

My long-term vision for this role is to create a world-class compliance organization that can stand on its own without any government assistance.  That means an efficient, highly competent, and fully resourced department that PAC can trust as it moves into more commercial and government work overseas.

Everything I've done in the past—whether in private practice or working in a business organization —has led me here.  When I worked at two large international law firms, I represented clients and acted as both a Compliance Monitor and compliance counsel. This allowed me to see both sides of the compliance landscape. While leading a legal/compliance team for a large defense contractor, I learned how to make decisions that were necessary, but also practical for the business. This confluence of factors has prepared me for my role: To help Panasonic grow its competitive functions so it can be a best-in-class solutions provider.

Last year, I was honored to be named Top Assistant General Counsel in Compliance by Chicago's First Chair Awards. I've also served on several boards and steering committees for prominent organizations. I completed my undergrad at Boston University and graduated cum laude from the Columbus School of Law at the Catholic University of America.

 

 


Kara Novaco Brockmeyer is a litigation partner based in the firm’s Washington D.C. office. She is a member of the White Collar & Regulatory Defense and Strategic Crisis Response and Solutions Groups, where her practice focuses on representing companies and individuals in anti-corruption, fraud and related government investigations and internal investigations, as well as advising on deal due diligence and compliance matters. Ms. Brockmeyer is ranked as a leading lawyer by Chambers USA (2020) where she is praised for her “enviable experience in major anticorruption investigations” and “expertise counseling clients on FCPA compliance programs.” Ms. Brockmeyer is also recommended by The Legal 500 US (2020).

Prior to joining Debevoise in 2017, Ms. Brockmeyer served as the Chief of the SEC Enforcement Division’s Foreign Corrupt Practices Act Unit and directed a nationwide team of attorneys and forensic accountants investigating violations of the FCPA. During her tenure as chief of the unit, she oversaw many of the agency’s largest and most complex FCPA investigations. She was also one of the principal authors of the SEC-DOJ Resource Guide to the Foreign Corrupt Practices Act, which is widely considered the definitive government-issued guide on the FCPA.

Over a seventeen-year career at the SEC, including five years as an assistant director, Ms. Brockmeyer led and personally conducted major investigations in all areas of SEC enforcement, including financial reporting, broker-dealer and investment adviser violations, and insider trading. She was also the founder and co-head of the division’s Cross-Border Working Group, an interdisciplinary group focused on addressing accounting fraud by companies based overseas.

Ms. Brockmeyer earned her J.D. from the University of Michigan Law School, magna cum laude, where she was also note editor of the Michigan Law Review. She received her B.A. from Williams College, cum laude.


Ms. Beamon, a partner in Davis Polk’s Litigation Department and a former federal prosecutor, has successfully represented institutions and individuals in their most critical situations. She is recognized by Chambers USA as a Band 1 lawyer for her work in the white collar and investigations space, with clients describing her as a “phenomenal lawyer” who is “very smart” and “incredibly strong” and who won praise for her handling of a number of “sophisticated cases.”

Her matters have included grand jury, regulatory and independent investigations, representing companies, board of directors and individuals in connection with allegations of securities fraud, foreign corrupt practices, anti-money laundering, criminal tax violations, pharmaceutical marketing violations, and sexual misconduct, among other areas. Her complex civil matters have involved allegations under the False Claims Act, consumer protection and whistleblower provisions, and other state and federal statutes. Ms. Beamon also has participated in a number of confidential internal investigations on behalf of clients and has advised corporations and boards of directors on matters of corporate governance and compliance. In addition, the FBI requested that she train its agents on insider trading.

Ms. Beamon served as an Assistant U.S. Attorney for the U.S. Attorney’s Office, Southern District of New York, where she conducted numerous investigations and criminal trials. She received her J.D., summa cum laude, from University of Pittsburgh School of Law and her B.A., with honors, from University of Notre Dame.


Andrew Stemmer is Deutsche Bank’s Head of Litigation & Regulatory Enforcement for the Americas, and a Managing Director and Associate General Counsel. Andrew has been at Deutsche Bank since 2013, prior to which he was associated with the law firm Cadwalader Wickersham & Taft LLP, where he focused on securities, complex commercial dispute and bankruptcy.


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, Jay Holtmeier, and Erin Sloane 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.


Patricia M. Byrne (“Trish”) is the VP & Associate General Counsel for International Compliance at BAE Systems, Inc., the wholly owned subsidiary of BAE Systems plc, a global defense contractor. 

Trish’s responsibilities include oversight of the Company’s anticorruption program and the International Trade team.  Her work involves advice and guidance on international business, conducting due diligence on third party business partners, policy administration, training on FCPA and anticorruption laws, FCPA focused merger and acquisition diligence, Offsets compliance, and export controls.  She manages a team of twelve people across the two functions.  In 2018 her Anticorruption team was awarded the ACC Global Counsel regulatory practice Team of the Year.

Trish joined BAE Systems, Inc. as Counsel for International and Domestic Compliance in 2008.  Prior to joining BAE Systems, Inc., Trish was a Counsel at WilmerHale, in Washington D.C. where her work focused primarily on FCPA investigations, and on reviewing, creating, and implementing anti-corruption compliance programs for multinational companies.

Trish received her JD from the University of California at Berkeley School of Law in 1999, and she graduated with a BA(Hons I)/LLB from the University of Otago, Dunedin, New Zealand in 1996.


Sharie Brown is a partner in the White Collar & Government Investigations Practice Group in the firm’s Washington, DC office. She is a recognized leader in ethics, compliance and internal investigations involving financial fraud and corruption for US and non-US companies. As a former federal prosecutor, a Mobil Oil compliance and ethics officer, and a leader of white collar and compliance practices at major law firms, Sharie is regarded as a trusted advisor, counselor and skilled investigator for board audit committees, corporate senior management and general counsels in several regions of the world. Her experience, leadership and frequent media contributions regarding corporate fraud and corruption make her an international thought leader in the field.

Sharie represents international corporations and conducts internal investigations, audits and transactional due diligence worldwide in the areas of the Foreign Corrupt Practices Act (FCPA), including the Dodd-Frank whistleblower program, the UK Bribery Act, OFAC sanctions compliance and international trade controls, corporate ethics and compliance, Section 301 tariffs and International Trade Commission proceedings,  and USA Patriot Act anti-money laundering. Sharie regularly represents US and non-US clients in complex matters involving the US Department of Justice, the US Department of Treasury, the US Securities and Exchange Commission, the US Department of Commerce, the US State Department, US Congressional Committees, and other local regulatory agencies.

Prior to joining Troutman Sanders, Sharie chaired the White Collar Defense & Corporate Compliance Practice Group and the Foreign Corrupt Practices Act (FCPA), Anti-Corruption and Corporate Compliance Practice Group at two leading law firms. Before joining these other law firms, Sharie worked at Mobil Oil Corporation’s Office of General Counsel, where she served as an ethics and compliance officer. In that capacity, she developed a worldwide ethics and compliance program, a code of conduct and employee training videos, as well as pamphlets on the FCPA, and Iran, Iraq, Cuba and Libya sanctions compliance. As Mobil's policy advisor in Corporate Planning and Economics, she handled trade, tax and sanctions policy issues. In addition, she directed Mobil's state government relations in key states prior to her Corporate Planning assignment.

Prior to Mobil, Sharie was an Assistant United States Attorney in the Eastern District of Pennsylvania, where she handled tax, bank fraud and securities fraud cases. She was commended by FBI Director William Sessions for her co-prosecution of a securities fraud RICO, among other enforcement agency commendations. Sharie also clerked for the Honorable Richard M. Bilby, United States District Court, District of Arizona.

Sharie has authored, contributed to or been the feature of numerous articles regarding her practice areas, in publications such as the Wall Street Journal, the National Law Journal, Law360.com, and many others. She has also presented or moderated numerous FCPA, anti-corruption, anti-money laundering, compliance, and OFAC sanctions panels all over the world, including the Middle East, Africa and Europe.  She serves as co- chair of the District of Columbia Bar Association’s International Law Community, and is an active member of the University of Pennsylvania Board of Overseers for the School of Arts and Sciences.


Thomas J. Koffer is the Global Head of Anti-Corruption & Economic Sanctions Compliance at Credit Suisse, where he oversees Credit Suisse’s enterprise-wide compliance program addressing the U.S. Foreign Corrupt Practices Act, the UK Bribery Act 2010, and other similar anti-corruption laws.  He also oversees compliance with economic and trade sanctions laws administered by the U.S. Office of Foreign Assets Control and other international regulators.  Previously, Thomas served as counsel at Wilmer Cutler Pickering Hale & Dorr, and as a law clerk for judges on the U.S. Second Circuit Court of Appeals and the U.S. District Court for the Southern District of New York.  Before earning a law degree, Thomas investigated political corruption matters at the New York County District Attorney’s Office.  He also previously served with the U.S. Vice President’s Domestic Policy Office.


Charles E. Cain is the Chief of the Foreign Corrupt Practices Act Unit within the Securities and Exchange Commission’s Division of Enforcement. He has been in the SEC’s FCPA Unit since its formation in 2010 and with the Division of Enforcement for nineteen years. As the Chief, his roles include oversight of the National FPCA program, coordination with domestic and foreign law enforcement, and supervision of individual investigations. During his tenure with the SEC, he has also been responsible for numerous significant cases in other areas including financial fraud, insider trading, offering fraud, market manipulation, disclosure fraud, and broker dealer practices. Mr. Cain is a graduate of The George Washington University Law School.


Damali Taylor is a skilled trial lawyer and former federal prosecutor who advises clients on white collar and civil litigation matters, as well as criminal, internal, and regulatory investigations. She conducts internal investigations on behalf of companies and audit committees across various industries in criminal and regulatory matters, including investigations by the U.S. Department of Justice, district attorney’s offices, state attorneys general and other regulatory agencies. Before rejoining O’Melveny as a partner, Damali spent six years as a federal prosecutor at the United States Attorney’s Office in the Northern District of California, where she supervised the Organized Crime Strike Force section. As a federal prosecutor, Damali handled complex fraud, corruption, racketeering, money laundering, and homicide cases. Prior to her tenure as an Assistant U.S. Attorney, she served as an Assistant District Attorney in the San Francisco District Attorney’s Office. Damali currently serves as Vice President and acting Chair of the San Francisco Police Commission, the oversight body responsible for implementing reform and imposing discipline for the San Francisco Police Department.


As a member of the Firm’s Litigation Group, Aisling O’Shea focuses her practice on criminal defense, government investigations and the Foreign Corrupt Practices Act.

Before joining Sullivan & Cromwell, Ms. O’Shea spent five years as a trial attorney in the Fraud Section of the U.S. Department of Justice’s Criminal Division. Within the Fraud Section, Ms. O’Shea was a member of the Foreign Corrupt Practices Unit. In addition to FCPA matters, she focused on fraud matters in securities and healthcare, as well as investigating and prosecuting other complex economic crimes. She also worked with other federal agencies, including the U.S. Securities and Exchange Commission, FinCEN and the Office of Foreign Assets Control.

Ms. O’Shea often handled active and covert investigations, pre-trial and grand jury proceedings, witness interviews and negotiated plea agreements. For one of her highest-profile matters, she and the case team were awarded the Homeland Security Investigations 2016 Outstanding Financial Investigation. This complex FCPA and money-laundering investigation involved corruption in a state-owned oil company in Venezuela and resulted in multiple guilty pleas and significant judgments.

Ms. O’Shea began her career as an associate at S&C, where she worked on complex financial investigations.