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The Foreign Corrupt Practices Act and International Anti-Corruption Developments 2013


Speaker(s): Alexandra A. Wrage, Alistaire Bambach, Brian L. Whisler, Charles E. Cain, Cheryl J. Scarboro, Christopher J. Cummings, Claudius O. Sokenu, Danforth Newcomb, David N. Lawrence, F. Joseph Warin, Gina Saviola, Glenn T. Ware, Greg D. Andres, Greta Lichtenbaum, Gustavo Carvajal Isunza, Howard O. Weissman, J. David Fielder, Jason A. Jones, Jordan A. Thomas, Kathryn Cameron Atkinson, Kenneth G. Yormark, Laurence A. Urgenson, Lucinda A. Low, Lynn A. Neils, Mark F. Mendelsohn, Mark Morrison, Martin J. Weinstein, Nina Henderson, Peter B. Clark, Raja Chatterjee, Richard W. Grime, Roger M. Witten, Sarah Z. Erickson, Steven A Tyrrell, Susan M. Ringler, Thomas McCarthy, Jr., Timothy L. Dickinson
Recorded on: May. 2, 2013
PLI Program #: 41921

Danforth Newcomb founded the anti-corruption practice at Shearman & Sterling LLP. His practice includes criminal and regulatory proceedings, internal investigations and compliance programs in Europe, Latin America, the Middle East, Asia and CIS countries.  He has conducted many multi-jurisdictional investigations including in Libya, Angola, Bonny Island Nigeria, China and Venezuela and acted as a DOJ & SEC sanctioned Independent Monitor in an Oil For Food prosecution and as a UN approved expert on compliance and ethics.   He also advises on Anti-Money Laundering, Economic Sanctions and sovereign immunity matters. Mr. Newcomb is the founding editor of the Shearman & Sterling FCPA Digest. 


Kenneth G. Yormark is a managing director for K2 Intelligence, where he leads the U.S.-based forensic accounting team. With more than 25 years of experience, he is an expert in complex global investigations and forensic and investigative services. Ken manages and conducts high-profile securities fraud, anti-corruption/Foreign Corrupt Practices Act (FCPA), and Ponzi scheme investigations involving public and private companies in all industries around the globe. He presents to regulatory and law enforcement agencies, boards, senior management, in-house and outside counsel, and auditors.

Working with clients in the financial services, manufacturing, real estate, pharmaceutical, telecommunications, and not-for-profit industries, Ken focuses on formulating and executing strategies regarding forensic accounting, financial investigations, securities litigation, and anti-corruption risk assessments. He is accomplished at assessing the vulnerability and reconstructing internal controls, compliance procedures, and accounting systems. He regularly works side by side with law firms investigating allegations of corruption and bribery, corporate malfeasance, and “cooking the books.” He has been qualified as an expert and testified in deposition and at trial in federal and bankruptcy courts.

Ken is an adjunct professor at Georgetown University Law Center, where he teaches “Accounting for Lawyers.” He is also a faculty member of the Practicing Law Institute and an adjunct faculty member of the Association of Certified Fraud Examiners (ACFE). He speaks nationally on fraud and anti-corruption at conferences and corporate events.

Ken received his B.S. from Queens College and completed graduate studies at New York University in real estate development analysis. He is a Certified Public Accountant (CPA), a Certified Fraud Examiner (CFE), is Certified in Financial Forensics (CFF), and is a Certified Anti-Money Laundering Specialist (CAMS).


Roger M. Witten, a partner at WilmerHale in New York, has for many years been one of the recognized leaders of the FCPA bar. He leads WilmerHale's 45-lawyer FCPA team, which regularly counsels well over 50 major US and non-US companies and typically has 20 enforcement matters pending before the DOJ and SEC at any one time. Mr. Witten has deep FCPA compliance counseling experience, has supervised numerous FCPA risk assessments, has broad experience providing FCPA counsel in the mergers and acquisitions context, has conducted internal investigations for companies, and has represented companies and individuals at the DOJ and the SEC in numerous publicly disclosed and other matters.  Mr. Witten is the original author, and now co-author with his partners Kimberly Parker and Jay Holtmeier, of the leading treatise, Complying with the Foreign Corrupt Practices Act. Mr. Witten has been named to numerous published "best lawyer" lists. He is a member of the District of Columbia and New York bars. Mr. Witten graduated from Dartmouth College and Harvard Law School. He clerked for The Hon. Harrison L. Winter on the US Court of Appeals for the Fourth Circuit and thereafter served as an Assistant Special Prosecutor in the Watergate Special Prosecution Force. 



He has distinguished himself as an outstanding FCPA practitioner, . . . he has a terrific boardroom presence and a practical approach to dealing with issues and governments around the world." –Chambers Global 2015

Larry Urgenson is a co-leader of the firms' Global Anti-Corruption & FCPA practice. Larry is widely recognized as one of the preeminent FCPA authorities in the United States. He has represented corporate and individual clients in FCPA and anti-corruption matters worldwide for nearly four decades. As noted in Chambers, Larry is "a brilliant lawyer and a leading light at the FCPA Bar." (Chambers USA 2016). He "is highly esteemed for his FCPA practice, which includes advising on statutory compliance and corporate representation in government investigations" (USA 2015), is "known for his experience in high-stakes investigations" (USA 2013) and "offers incredible knowledge in the FCPA area . . . he has great judgment" (USA 2012). Clients praise Larry and state that, "There simply isn't a more client-sensitive strategist out there" (Chambers Global 2016).

Larry was named Benchmark Litigation Star in 2014, 2015, 2016 and 2017. He was also recognized nationally as one of 8 FCPA Masters at the first annual Main Justice Best FCPA Lawyers Client Service Awards in 2013. Additionally, he is a sought-after writer and speaker on white collar matters and is currently the Chairman of the Board of Editors of the Business Crimes Bulletin.

Prior to joining private practice, Larry held key leadership positions at the US Department of Justice (DOJ). As the DOJ's Acting Deputy Assistant Attorney General, he primarily supervised the Fraud Section, General Litigation and Legal Advice Section, and Office of Policy and Management Analysis. Additionally, he testified before various congressional committees regarding the Department's white collar crime initiatives. He also served as the DOJ's Chief of the Fraud Section for the Criminal Division, where he advised US Attorneys on white collar crime issues, supervised the prosecution of bank, securities, and defense procurement frauds, and oversaw the FCPA Unit and the Defense Procurement Fraud Unit. Earlier in his career, Larry served as a Chief Assistant US Attorney for the Eastern District of New York. Larry received the Attorney General's Award for Distinguished Service and the Edmund J. Randolph award for Outstanding Service.


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 counselling and advice, representation in disputes between commercial parties and host governments, including disputes involving issues of fraud and corruption.  She received a #1 Ranking, Chambers Global 2010-2017, International Trade: FCPA Experts.  Ms. Low is listed in Best Lawyers in America 2012-2018, International Arbitration: Government and International Trade and Finance Law. Ms. Low is in Washington, DC Super Lawyers, International, 2014-2018.

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, in 2017, she received the Outstanding Career award from the Global Investigations Review, which in 2015 named her to its “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.


Claudius Sokenu, a former senior counsel with the United States Securities and Exchange Commission, Division of Enforcement, is Deputy General Counsel, Global Head of Litigation, and Global Head of Compliance at Andeavor, a Fortune 100 energy company.  Claudius oversees all of Andeavor’s litigation, internal and government investigations, regulatory compliance, and the ethics and compliance program.

Prior to joining Andeavor, Claudius was a litigation partner at Shearman & Sterling’s New York, Washington, DC, and London offices where his practice focused on representing multinational public and private companies, hedge funds, private equity firms, broker-dealers, investment banks, investment advisers, accounting firms, and their officers, directors, and employees in complex commercial litigations, securities enforcement actions and litigations, including class actions and FINRA arbitrations, white collar criminal defense, derivative actions, congressional investigations, internal investigations, and corporate crisis management.  Claudius has extensive experience in handling delicate high-profile matters that require concurrent representation in the civil, criminal, and political spheres.

Claudius is widely recognized as a leading securities enforcement, white collar crime and Foreign Corrupt Practices Act (FCPA) practitioner.  In nearly two decades in private practice, Claudius represented domestic and multinational compa­nies and their employees in all aspects of FCPA internal investigations, enforcement actions, and compliance matters before the SEC, the United States Department of Justice (DOJ), the United Kingdom’s Serious Fraud Office, and other civil and criminal authorities in the United States and abroad.  Claudius has represented Boards of Directors, Audit Committees, officers, senior management and employees of multinational companies in all anticorruption investigations in dozens of countries and on virtually every continent.

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

Consistently ranked by Chambers USA and Chambers Global for his investigative, regulatory, and securities enforcement practice (2014, 2013, 2012, 2011), named a Litigation Star by Benchmark Litigation (2016, 2015), Latin Lawyer 250 for White-Collar Crime and Compliance (2013), named a rising star by Ethisphere in its national annual rankings of “Attorneys Who Matter” (2012), named a “Top Lawyer” by The Network Journal (2011), named by Main Justice as one of the Best FCPA Lawyers Outside the Beltway (2011), Diversity & The Bar’s “Leading Law Firm Rainmakers” (2010), and recognized by Securities Law 360 as one of its 10 under 40 (2007), Claudius has represented major companies and/or their officers and directors, including Bank of New York, Bank of America, CIBC World Markets, Northern Trust, Allianz SE, AIG, Cantor Fitzgerald, CVS Caremark, PepsiCo, GlaxoSmithKline, Ernst & Young, Avon Products, Arthur Andersen LLP, Amgen, Walmart, Bristol-Myers Squibb, KraftHeinz, Embraer, Cardinal Health, and TV Azteca before prosecutors and regulators in the United States and abroad and in federal and state courts on bet-the-farm matters.

Claudius was an Adjunct Professor of Law at Georgetown University Law Center in Washington, DC where he taught advanced level securities enforcement and litigation courses.  He has lectured and published extensively on securities enforcement and litigation matters and has been quoted in the financial press on a variety of securities law issues.  Claudius earned his LL.B (with Upper Class Honors) from London South Bank University, an LL.M in Corporate and Commercial Law from the London School of Economics and King’s College London, University of London, and an LL.M in Securities and Financial Regulation from Georgetown University Law Center.


David Lawrence is a Managing Director and an Associate General Counsel. He is the global head of the Business Intelligence Group, which is comprised of a number of attorneys, former government and regulatory officials, and analysts located in the United States, United Kingdom and Asia. The group has global responsibility for a wide range of regulatory and due diligence matters. In this capacity, David provides coverage for the Investment Banking, Fixed Income, Merchant Banking, Equities and Asset Management divisions.

David serves on the firm's Commitments, Capital, Credit Markets, Diverse Business Engagement, and Private Equities Group Committees, and regularly advises a number of the firm's investment committees. He is also an observer of the Middle Market Loan Committee for Goldman Sachs Bank USA and serves as senior advisor to the Legal, Global Compliance, and Internal Audit (LCA) Black Network. David joined Goldman Sachs in 1993 and was named managing director in 1999.

Prior to joining the firm, David was an assistant United States attorney for the United States Attorney's Office, Southern District of New York for approximately ten years. During his tenure, he served as the deputy chief of the Criminal Division and chief of the Public Corruption and General Crimes Units.

David serves on the Board of Directors of John Jay College of Criminal Justice.

David helped establish Regulatory Data Corp (RDC) - a data and technology risk-management company, focused on corporate compliance and reporting solutions to such issues as money laundering, fraud, government corruption and terrorism financing.

David earned a JD from New York University in 1980 and a BA, magna cum laude, from Brandeis University in 1975.


Gina Saviola is Senior Compliance Counsel at Jacobs Engineering Group and is based in Los Angeles.  Gina has over twelve years of experience implementing and overseeing global anti-corruption programs for Occidental Petroleum Corporation and Japan-based Sumitomo Electric Industries Ltd.  Prior to going in-house, Gina was an attorney in the enforcement division of the SEC and a white collar criminal defense attorney.  She received her B.A. in Classical Studies from Duke University and her J.D. from the University of Virginia School of Law.


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

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

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

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


Greg Andres returned to Davis Polk after more than 12 years as a federal prosecutor in both New York and Washington, D.C.  Most recently, he served as a Deputy Assistant Attorney General in the Criminal Division at the Department of Justice.  In that capacity, he supervised many of the Department's most significant white-collar prosecutions, including the Foreign Corrupt Practices Act (FCPA) cases nationwide. He has represented the Department before Congress on various issues, testifying before both houses. From 2007 to 2010, Mr. Andres served as Chief of the Criminal Division in the U.S. Attorney's Office for the Eastern District of New York, where he supervised more than 100 federal prosecutors in a wide range of investigations and prosecutions. He has tried and supervised a variety of high-profile cases involving financial fraud, organized crime and terrorism offenses. Mr. Andres is the recipient of numerous awards in the legal profession, including: The Attorney General's Distinguished Service Award (2008), the Department of Justice Director's Award (2003, 2005, 2010) and the Henry L. Stimson Medal (awarded by the New York City Bar Association). In 2005, the National Law Journal named Mr. Andres to the "Top 40 Under 40" list.


Greta Lichtenbaum is a partner in the Washington, DC office of O’Melveny specializing in compliance with US laws that govern international business transactions and trade, including US economic sanctions, export controls, anti-corruption, foreign investment, money laundering, antiboycott, and customs laws.

In addition to advising clients on the application of these laws, Greta assists in all aspects of managing compliance with these laws, including developing corporate compliance programs, conducting internal investigations relating to potential violations of these laws, and representing companies before the relevant agencies in connection with enforcement proceedings, clearances, license requests, and government inquiries.

Greta has repeatedly been recognized as a leading lawyer in the area of export controls and economic sanctions by Chambers USA (Band 1), Chambers Global (Band 1) and The Legal 500 US. She is a frequent speaker on topics related to international trade and has written extensively on these topics.

Greta graduated from Harvard Law School in 1990. While in law school, she served as Managing Editor of the Harvard Human Rights Journal and a member of the International Law Society.



Gustavo Carvajal Isunza, Bilingual attorney with extensive experience in the fields of administrative law in particular in matters related to the (i) environment, and (ii) anti-corruption.

Professional Experience

SOLÓRZANO, CARVAJAL, GONZÁLEZ & PÉREZ CORREA, S.C., Mexico City                  1995-2013
Partner 

  • Represented Metalclad Corporation, a U.S. public company, in its successful Investor-State Arbitration vis a vis the United Mexican States related to the construction and operation of a hazardous waste lanfill. Offered as expert witness by the Investor and called by Respondent for Direct and Cross Examination during Oral Hearing.
  • Represents Abengoa, a Spanish public company in its ongoing Investor-State Arbitration vis a vis Mexico related to the closure of environmental projects in Hidalgo. Acts as lead counsel.
  • Represents the Commission for Environmental Cooperation, an international entity created by the NAFTA, providing consulting services regarding environmental matters that have been raised to their attention by the NAFTA Parties or nationals of the NAFTA Parties.
  • Represents Carrix/Goldman Sachs in the permitting of their Port Terminal in Tuxpan, Veracruz.
  • Advices several Fortune 500 companies in anti-corruption policy and law in Mexico.
  • Represents the firm in all TRACE activities. Solcargo is TRACE´s partner firm in Mexico.
  • Represents the National Water Commission (Conagua) in a multi million litigation against Carlos Slim´s companies (Grupo Carso) in connection with the construction of the Tunel Emisor Oriente.
  • Represents the Federal Commission of Electricity (CFE) in several arbitrations against independent power producers and other contractors.
  • Advices Monsanto, the world leading company dedicated to sustainable agriculture, in their business operations in Mexico.
  • Represents several UK based Companies, among others, Eco-Securities, Ener-G and Biogas Technology Ltd. in matters related to energy and CDM projects,
  • Retained by the Federal Government, both by the Executive and Legislative Branches, to draft legislation on wastes, water, climate change, anti-corruption, and air pollution.

MINISTRY OF FISHERIES, Mexico City                                                                            
1991-1992; 1994
Chief of Staff for the Minister

Education

HARVARD UNIVERSITY, United States of America    
Master in Public Policy, 1994

UNIVERSIDAD NACIONAL AUTÓNOMA DE MÉXICO, Mexico City
Bachelor in Law, with honors, 1991

Academic Activities

Administrative Law Professor at the ITAM, UNAM and the Universidad Panamericana, 1994-2013


Howard O. Weissman is Vice President and Associate General Counsel-International for Lockheed Martin Corporation where he is responsible for providing international legal advice to all elements of the Corporation, including its international field offices, foreign subsidiaries and international joint venture companies.  Mr. Weissman has specific expertise with U.S. laws and regulations directly impacting international business operations such as the FCPA and U.S. antiboycott laws, as well as the International Traffic in Arms Regulations and Export Administration Regulations. Prior to joining Martin Marietta in 1988, Mr. Weissman held international legal positions at the Communications Satellite Corporation (COMSAT) in Washington, D.C., as well as two international law firms. 

 


J. David Fielder joined INT as the Manager of External Investigations in December 2011. His prior experience includes two years as the Assistant Inspector General for Investigations at the U.S. Securities and Exchange Commission (SEC) where he supervised investigations of the SEC's activities in connection with the Madoff and Stanford Ponzi schemes, and several other matters. He also served at the SEC for several years as a Branch Chief and senior counsel in the Division of Enforcement where he led key parts of the government's case against Enron. In addition to his experience at the SEC, Mr. Fielder was a partner in the Washington, D.C. office of Haynes and Boone, LLP, and Special Assistant Counsel to the President of the United States. He received his B.A. magna cum laude from Washington University in 1987, a master's in hydrogeology/environmental geology from Pennsylvania State University in 1989, and his J.D. from the University of Michigan in 1992.




Jason Jones is an Assistant Chief in the FCPA Unit of the Fraud Section. Prior to joining the Criminal Division, Jason was Chief of the Violent Crimes and Terrorism Section in the U.S. Attorney's Office for the Eastern District of New York, supervising some of the most successful complex racketeering and international terrorism prosecutions in the country. 

Jason has prosecuted and supervised dozens of complex federal cases. Among several other matters, Jason secured convictions against terrorists who plotted to blow up JFK Airport; corporate executives who perpetrated a $2.2 billion securities fraud; and dozens of violent gang members, including two death penalty trials.

Jason's experience also includes the prosecution of a wide range of other federal crimes, including the Foreign Corrupt Practices Act, money laundering, tax fraud, narcotics and firearms trafficking, child pornography, immigration violations and counterfeiting. Jason also participated in the investigation of international terrorists held at Guantanamo Bay, Cuba.

Jason has been the recipient of the Attorney General's Award for Excellence in Furthering the Interests of U.S. National Security, the Federal Law Enforcement Foundation's Federal Prosecution Award, and the U.S. Attorney's Office Award for Excellence in Criminal Litigation.


Jordan A. Thomas concentrates his practice on investigating and prosecuting securities fraud on behalf of whistleblowers and institutional clients. As Chair of the Firm's Whistleblower Representation practice, Jordan protects and advocates for whistleblowers throughout the world who have information about possible violations of the federal securities laws. He created, and serves as the editor for, www.secwhistlebloweradvocate.com, a website dedicated to helping responsible organizations establish a culture of integrity and courageous whistleblowers to report possible securities violations-without personal or professional regrets.

A longtime public servant and seasoned trial lawyer, Jordan joined Labaton Sucharow from the Securities and Exchange Commission where he served as an Assistant Director and, previously, as an Assistant Chief Litigation Counsel in the Division of Enforcement. He had a leadership role in the development of the SEC Whistleblower Program, including leading fact-finding visits to other federal agencies with whistleblower programs, drafting the proposed legislation and implementing rules and briefing House and Senate staffs on the proposed legislation. He is also the principal architect and first National Coordinator of the Commission's Cooperation Program, an initiative designed to facilitate and incentivize individuals and companies to self-report securities violations and participate in its investigations and related enforcement actions. In recognition of his important contributions to these national initiatives, while at the SEC, Jordan was a recipient of the Arthur Mathews Award, which recognizes "sustained demonstrated creativity in applying the federal securities laws for the benefit of investors," and, on two occasions, the Law and Policy Award.

Throughout his tenure at the SEC, Jordan was assigned to many of its highest-profile matters such as those involving Enron, Fannie Mae, UBS, and Citigroup. He successfully investigated, litigated and supervised a wide variety of enforcement matters involving violations of the Foreign Corrupt Practices Act, issuer accounting fraud and other disclosure violations, audit failures, insider trading, market manipulations, offering frauds, and broker-dealer, investment adviser and investment company violations. His cases resulted in monetary relief for harmed investors in excess of $35 billion.

Prior to joining the Commission, Jordan was a Trial Attorney at the Department of Justice, where he specialized in complex financial services litigation involving the FDIC and Office of Thrift Supervision. He began his legal career as a Navy Judge Advocate on active duty and continues to serve as a senior officer in its Reserve Law Program. Earlier, Jordan worked as a stockbroker.

Jordan is a board member of the City Bar Fund, which oversees the City Bar Justice Center, the pro bono affiliate of the New York City Bar Association. He also serves as the Chair of the Investor Rights Committee of the District of Columbia Bar.

Throughout his career, Jordan has received numerous awards and honors. Most recently, Jordan was named a 2015 Top Thought Leaders in Trust by Trust! Magazine and a 2014 Superstar by Corporate Responsibility Magazine. In 2012, he was named a Legal Rebel by the American Bar Association Journal in recognition of his trailblazing efforts in the legal field. Ethisphere Institute, an internationally recognized think tank, selected Jordan as a Rising Star in its listing of 2012 Attorneys Who Matter, which recognizes leading practitioners in the world of corporate ethics and compliance. While at the SEC, Jordan received four Chairman's Awards, four Division Director's Awards and a Letter of Commendation from the United States Attorney for the District of Columbia. He is also a decorated military officer, who has twice been awarded the Rear Admiral Hugh H. Howell Award of Excellence-the highest award the Navy can bestow upon a reserve judge advocate. Jordan has received an AV Preeminent rating, the highest attorney rating available, from the publishers of the Martindale-Hubbell legal directory.

Jordan is a nationally sought after writer, speaker and media commentator on securities enforcement, corporate ethics, and whistleblower issues.


Joseph Warin is chair of the nearly 200-person Litigation Department of Gibson Dunn’s Washington, D.C. office, and he is co-chair of the firm’s global White Collar Defense and Investigations Practice Group. He served as Assistant United States Attorney in Washington, D.C., and  was awarded a Special Achievement award by the Attorney General.  As a prosecutor, he tried more than 50 jury trials.

Mr. Warin’s areas of expertise include representation of corporations in complex civil litigation, white collar crime, and regulatory and securities enforcement – including Foreign Corrupt Practices Act investigations, False Claims Act cases, special committee representations, compliance counseling and class action civil litigation. His clients have included corporations, officers, directors and professionals in regulatory, investigative and trial matters.  Mr. Warin has been selected to serve on insurance company panels for securities class actions.  He is a member of the Board of the International Association of Independent Corporate Monitors.

Mr. Warin is continually recognized annually in the top-tier by Chambers USA, Chambers Global, and Chambers Latin America for his FCPA, fraud and corporate investigations expertise.  Who’s Who Legal named Mr. Warin to their 2019 "Thought Leaders: Global Elite" list for Business Crime Defense - Corporate and Investigations.  In 2018, Mr. Warin was selected by Chambers USA as a “Star” in FCPA, a “Leading Lawyer” in the nation in Securities Regulation: Enforcement, and a “Leading Lawyer” in the District of Columbia in Securities Litigation and White Collar Crime and Government Investigations.  In 2017, Chambers USA honored Mr. Warin with the Outstanding Contribution to the Legal Profession Award, calling him a “true titan of the FCPA and securities enforcement arenas.”  He has been listed in The Best Lawyers in America® every year from 2006 - 2018 for White Collar Criminal Defense. He has been recognized by Benchmark Litigation as a U.S. White Collar Crime Litigator “Star” for nine consecutive years (2011-2019).

Mr. Warin’s group was recognized by Global Investigations Review in 2018 and three years previously as the leading global investigations law firm in the world.  Global Investigations Review reported that Mr. Warin has now advised on more FCPA resolutions than any other lawyer since 2008. He has been hired by audit committees or special committees of public companies to conduct investigations into allegations of wrongdoing in a wide variety of industries including energy, oil services, financial services, healthcare and telecommunications.


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).


Lynn A. Neils’ practice focuses on representing companies and individuals on matters related to white collar criminal defense, internal investigations, regulatory enforcement, corporate compliance and complex commercial litigation. Drawing on her extensive prosecutorial, corporate and private practice experience that spans more than twenty-five years, she has counseled clients in large-scale federal criminal investigations, as well as advised clients on the Foreign Corrupt Practices Act (FCPA) and other regulatory matters involving the SEC and federal, state and foreign regulators. Ms. Neils has significant trial experience in both the federal and state courts.

Ms. Neils is highly regarded by clients for her ability to "look at the full picture to get an understanding of what is going on" and her "impressive level of depth” (Chambers USA, Litigation: White-Collar Crime & Government Investigations, 2015).

Ms. Neils served as an Assistant United States Attorney in both the Southern District of New York (SDNY) and the District of New Jersey. During her more than 11 years as an Assistant United States Attorney, Ms. Neils worked on a wide variety of complex white collar cases, including securities fraud, accounting fraud, bank fraud, Bank Secrecy Act, tax fraud, wire fraud, money laundering, health care fraud, art fraud, insurance fraud, FCPA, U.S. sanctions and obstruction of justice matters.

In 2004, she was promoted to Chief of the Major Crimes Unit in the SDNY where she supervised approximately 20 senior Assistant United States Attorneys in handling the investigation and prosecution of a wide variety of complex, and often multinational, white collar cases. In that role, she coordinated with multiple prosecutorial and regulatory offices, including many outside the United States, including the U.K. Serious Fraud Office and the Financial Services Agency.  She also acted as a liaison with the banking regulators in New York, including the Federal Reserve Bank, the Federal Deposit Insurance Corporation and the Office of the Comptroller of the Currency.

For several years, Ms. Neils also served as Senior Counsel at Johnson & Johnson and was responsible for handling a large caseload of criminal and civil matters; conducting internal investigations; advising on compliance and regulatory matters, including those related to the FCPA; and conducting training of employees on regulatory and legal matters, including those related to the FCPA and other anti-corruption laws and regulations.


Martin J. Weinstein is a partner in Willkie Farr & Gallagher LLP’s Litigation Department, Chair of the Compliance, Investigations & Enforcement Practice Group and a member of the firm’s Executive Committee. Mr. Weinstein graduated from Dartmouth College and the University of Virginia School of Law. Mr. Weinstein represents corporations, organizations and individuals in a wide variety of sensitive matters ranging from bribery, fraud, whistleblower and corruption matters worldwide to Congressional inquiries into campaign contributions, as well as the last Pete Rose investigation on behalf of the Commissioner of Major League Baseball. His practice has covered almost every major enforcement, compliance or financial fraud topic in almost every industry, spanning over 60 countries in every region of the world. Mr. Weinstein is a widely recognized authority in the US Foreign Corrupt Practices Act (FCPA), is recognized in Chambers and has been an expert witness on a number of occasions. He is co-author of The Foreign Corrupt Practices Act: Compliance, Investigations and Enforcement, a comprehensive practitioner’s handbook. He is a community leader serving on a variety of boards including the Chesapeake Bay Trust, Washington, DC Community Foundation and the Landon School.


Nina Henderson is a Director of CNO Financial Group (Bankers Life, Washington National, Colonial Penn insurance companies), (NYSE) Chair Compensation, member Audit, Risk and Investment Committees, Director of Hikma Pharmaceuticals PLC (LSE) Audit, Remuneration and Nomination/Governance Committees, Board Employee Engagement Lead, Director of IWG PLC (formerly Regus) (LSE) global worksite Provider, Chair Remuneration, member Audit and Governance Committees, Board Employee Engagement Lead.

She has served as a Director of AXA Financial Inc. and The Equitable Companies (NYSE) Audit, Investment and Finance/Risk Committees (15 years); Del Monte Foods Company (NYSE) Lead Director and Chair Nominating & Corporate Governance Committee (9 years), sold to KKR; Pactiv Corporation (NYSE), Audit Committee (10 years) sold to Reynolds Holdings; Royal Dutch Shell, PLC (LSE/NYSE) and its predecessor company The Shell Transport and Trading Co. PLC (LSE/NYSE) Audit, Remuneration, Corporate/Social Responsibility Committees (9 years); Hunt Corporation (NYSE) Audit and Compensation Committees (10 years), sold to Berwind and Walter Energy Inc. (NYSE) metallurgical coal for the global steel industry Audit and Health/Safety &  Environmental Committees (3 years), sold to Warrior Met Coal, LLC.

At Bestfoods ($9.4 billion) and its predecessor company CPC International (NYSE), she was one of fourteen (14) corporate officers as President and Corporate Vice President of Bestfoods Grocery $1.3 billion U. S. consumer business (Hellmann’s, Skippy, Mazola, Mueller's, etc.); Corporate Vice President Bestfoods Food Service Global Development $1.7 billion in Europe, Middle East, Asia, Latin America, North America; President and Corporate Vice President and of Bestfoods Specialty Markets Group in Canada, United States, Caribbean, Worldwide Exports food/non-food brands for North American General Market, Hispanics and Asian consumers. Prior to her general management positions, she held numerous executive marketing positions including Vice President Bestfoods Baking (direct store door delivery of fresh baked goods). Bestfoods was acquired by Unilever.

Nina is Vice Chair, Board of Trustees Drexel University, including the Drexel College of Medicine, Chair of the Academic Affairs Committee, and a member of Executive and Finance Committees; a Director of Visiting Nurse Service of New York Finance and Strategic Committees, a Director of the Foreign Policy Association and President of the Kent Land Trust Foundation.

She is a graduate of Drexel University, B.S. with honors. She received the A.J. Paul Drexel Distinguished Alumni Award and is a member of the Drexel 100.

As a global General Manager and Board Director of complex multi-national corporations, her expertise includes operational management of North American and International businesses, strategy development and execution, brand marketing, mergers/acquisitions/joint ventures and corporate governance. Industry experience spans consumer products (food and non-foods), energy (oil, natural gas, bio-fuels, wind, solar, tar sands mining, chemicals) and metallurgical coal mining for the steel industry, financial services (insurance, mutual funds), business services and health care (pharmaceuticals, health insurance, home care, clinical practice, and physician education).

She speaks frequently on business strategy, globalization, higher education and corporate governance for McKinsey, Rand Corporation, NACD, KPMG, Deloitte, PWC, Conference Board, Practicing Law Institute, NYSE/Euronext and Bogazigi (Bosphorus) University (Istanbul).


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

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

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

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

Peter was presented with the 1998 Award for Outstanding Government Lawyer by the American Bar Association Section of International Law and Practice for his role in enforcing the FCPA and in negotiating the OECD Convention. Most recently, he was recognized as an “FCPA Master” by Main Justice for his record of achievement in anti-corruption defense work.  Ethisphere Institute honored Peter in their 2012 Attorneys Who Matter Hall of Fame, Ethisphere's highest honor given to a practicing attorney, and named him a "Top Gun" lawyer in its 2011 Attorneys Who Matter.  Peter was also recognized by Who's Who Legal's The International Who's Who of Business Crime Defence Lawyers in 2014 and 2012, and by Benchmark Litigation.   Peter has been a member of the Advisory Committee on International Economic Policy of the U.S. Department of State. He is a member of the Board of Directors of Transparency International-USA.

Peter is a graduate of Brown University and the University of Pennsylvania Law School. He has lectured extensively before professional associations both domestically and internationally. He is admitted to practice in the District of Columbia and the State of New York.


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

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

Prior to joining Gibson Dunn, Richard spent over nine years in the Division of Enforcement at the Securities and Exchange Commission in Washington, DC.  In his last four years at the Commission he was an Assistant Director. Mr. Grime is currently highly ranked in Chambers USA Nationwide FCPA and Chambers Global FCPA and was recently selected by his peers for inclusion in The Best Lawyers in America© 2016 in the field of Criminal Defense: White Collar.  He is also a longstanding and frequent speaker to legal and industry practitioners particularly on anti-corruption and securities enforcement topics.

Mr. Grime received his law degree from Oxford University.


Sarah Erickson is the Associate General Counsel - International for Ecolab Inc., responsible for Ecolab's legal matters outside the United States.  She has primary responsible for Ecolab's FCPA compliance program. In addition, Sarah has handled numerous international acquisitions and other transactions as well as serving in a variety of other roles including antitrust, dispute and litigation management, corporate governance and SEC compliance.   

With sales of $11 billion and more than 40,000 employees, Ecolab Inc. (NYSE: ECL) is the global leader in water, hygiene and energy technologies and services that provide and protect clean water, safe food, abundant energy and healthy environments. Ecolab delivers comprehensive programs and services to the food, energy, healthcare, industrial and hospitality markets in more than 160 countries.

Sarah received her B.A. from the University of Minnesota Duluth, graduating magna cum laude and received her J.D. from the University of Minnesota, graduating cum laude. 




Susan Ringler joined Alcoa in June 2013 as Vice President and Chief Ethics & Compliance Officer.  In this function, Sue leads Alcoa's global ethics and compliance programs and ensures alignment to Alcoa's Values as well as compliance with applicable regulations. She oversees Alcoa’s Anti-Corruption and Trade Compliance Programs.

Prior to joining Alcoa, she was a Deputy General Counsel at Xylem Inc., a global water technology company that was spun off from ITT Corporation in 2011. She is the former Sr. Counsel for International Compliance at ITT, where she where she created and implemented its first global anti-corruption program.

Earlier in her career, Sue served as General Counsel under Chairman Paul Volcker of the Independent Inquiry Committee investigating the United Nations Oil for Food Programme, a large international corruption investigation spanning six continents. She also investigated fraud and corruption in World Bank-financed projects, and worked on developing best practices for investigations. As part of her work with the American Bar Association's Central and East European Law Initiative, Sue developed and managed criminal justice reform assistance and training programs in Russia and the former Soviet Republics. From 1985-1998, Sue served as an Assistant U.S. Attorney with the U.S. Attorney’s Office for the District of Maryland, where she worked in the White Collar Fraud Group prosecuting complex federal fraud and corruption cases.

Sue earned a Juris Doctor Degree from Catholic University, Columbus School of Law, Washington, D.C., where she was a member of the Law Review.   She obtained her bachelor's degree in Government from Franklin and Marshall College in Lancaster, PA.

Sue is a member of the board of directors of the CEELI Institute in the Czech Republic, a global institution dedicated to enhancing the rule of law by providing legal education to lawyers, judges, prosecutors and other reformers worldwide; a member of the Sanctions Board for the African Development Bank; serves on the American Conference Institute's Global Anti-Corruption Advisory Board; and is a member of the Franklin & Marshall College Leadership Council.


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

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

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

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

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


A partner in the Litigation Department, Mark Mendelsohn is co-chair of the Anti-Corruption & FCPA Group, and a member of the White Collar and Regulatory Defense, Internal Investigations, and Securities Litigation Practice Groups. Prior to joining Paul, Weiss, Mark served as the deputy chief of the Fraud Section of the Criminal Division of the United States Department of Justice (DOJ), and is internationally acknowledged and respected as the architect and key enforcement official of DOJ’s modern Foreign Corrupt Practices Act (FCPA) enforcement program.

Mark’s practice emphasizes white collar matters, internal corporate investigations, and compliance counseling. He regularly represents clients in FCPA and corruption-related internal investigations, designing and implementing compliance programs, transactional anti-corruption diligence, and responding to and defending against government investigations, prosecutions, and trials on behalf of both business entities and individuals.

As deputy chief of the Fraud Section from 2005 to 2010, Mark was responsible for overseeing all DOJ investigations and prosecutions under the FCPA, and for supervising a team of trial attorneys with respect to investigations and prosecutions of a wide variety of federal white collar crimes including money laundering, mail and wire fraud, procurement fraud, Arms Export Control Act and International Traffic in Arms Regulations (ITAR) violations, and violations of economic and trade sanctions laws and regulations, including with respect to the United Nations Oil for Food Program. During his tenure, Mark handled hundreds of voluntary disclosures of illicit corporate payments, worked closely with attorneys in the Division of Enforcement at the U.S. Securities and Exchange Commission, helped establish and worked closely with the Federal Bureau of Investigation’s FCPA squad at the Washington Field Office, negotiated numerous corporate plea, deferred and non-prosecution agreements on behalf of DOJ, and participated in the appointment of, interaction with, and reporting by more than 16 corporate compliance monitors. Mark led an effort to forge closer working relationships with foreign regulators in connection with transnational bribery cases, resulting in coordinated settlements with the Munich Public Prosecutor in Germany in the Siemens prosecutions and coordinated settlements with the U.K.’s Serious Fraud Office in the BAE and Innospec prosecutions, among others. Mark was also responsible for  administering DOJ’s FCPA Opinion Release Procedure, including issuing the seminal opinion on FCPA transactional diligence and successor liability (Op. Rel. 08-02).

In addition to case-related responsibilities, Mark had significant policy responsibilities, including principal policy responsibilities related to the Organisation for Economic Co-operation and Development (OECD) Anti-bribery Convention. As a member of the U.S. delegation to the OECD Bribery Working Group, Mark served as a lead examiner for the follow-up review of Japan’s implementation of the OECD Anti-bribery Convention, played a key role in peer review of the United Kingdom including consultation regarding its Bribery Act of 2010, negotiated the 2009 Anti-Bribery Recommendation, and played a leading role in the drafting and adoption of the OECD’s “Good Practice Guidance on Internal Controls, Ethics and Compliance.”

During his tenure administering the DOJ’s FCPA enforcement program, the DOJ brought more than 50 prosecutions against corporations for violations of the FCPA and related offenses, resulting in more than $1.5 billion in criminal penalties. During that same period, DOJ brought approximately 80 prosecutions against individuals. Among the notable prosecutions were the following: U.S. v. Siemens AG, et al.; U.S. v. Kellogg Brown & Root, LLC and U.S. v. Albert “Jack” Stanley; U.S. v. Congressman William J. Jefferson; U.S. v. BAE Systems plc; U.S. v. Baker Hughes, et al.; U.S. v. Titan Corp.; U.S. v. Statoil ASA; U.S. v. Monsanto; Lucent Technologies, Inc.; U.S. v. Willbros Group, Inc., et al.; U.S. v. Christian Sapsizian, et al.; U.S. v. Viktor Kozeny and Frederick Bourke, Jr.; U.S. v. Gerald and Patricia Green; U.S. v. Innospec, Inc.; and U.S. v. Daimler AG.

Prior to joining the Fraud Section, Mark was senior counsel in the DOJ’s Computer Crime and Intellectual Property Section in Washington, D.C., and prior to that served for nearly six years as an assistant U.S. attorney in the U.S. Attorney’s Office in the Southern District of New York. During his service with the U.S. Attorney’s Office, Mark tried numerous cases to verdict and argued several appeals before the United States Court of Appeals for the Second Circuit. As a federal prosecutor, Mark was a recipient of the Attorney General’s Award for Distinguished Service for the “Investigation into Corrupt Payments by Siemens AG,” and a recipient of the Assistant Attorney General’s Award for “The Safeguarding and Maintenance of Confidence in the American Marketplace.” Mark has been recognized by Ethisphere Institute in 2011 as a “Top Gun” among “Attorneys Who Matter,” in 2009 as a “Government Star” among “Attorneys Who Matter In Corporate Compliance,” and in 2007 and 2008 as one of the “100 Most Influential People in Business Ethics.” Mark has been selected to Lawdragon “500 Leading Lawyers in America” numerous times. Mark is also ranked by Chambers for his work as an FCPA practitioner.

Mark has spoken frequently as a faculty member, panelist and keynote speaker at numerous FCPA, anti-corruption, corporate compliance, securities fraud, money laundering, and white collar crime programs and conferences. He teaches International Criminal Law as a visiting professor at the University of Virginia School of Law and has also been an adjunct lecturer-in-law at Columbia Law School. Mark is member of the Edward Bennett Williams Inn of Court and a member of the Board of Directors of Transparency International-USA.


Cheryl Scarboro, formerly an Associate Director in the SEC’s Division of Enforcement and the first Chief of the SEC’s FCPA Unit, is a Partner in the Washington, D.C. office of Simpson Thacher & Bartlett LLP and a member of the Firm’s Government and Internal Investigations Practice. She represents corporations, financial institutions and individuals in government investigations and other regulatory enforcement proceedings. Cheryl handles sensitive internal investigations on behalf of management, boards, and special committees, and routinely counsels clients on compliance programs, SEC reporting, disclosure and corporate governance requirements. 

Selected representations include:

  • Representation of a former employee of a mining company in an action brought by the SEC alleging accounting violations relating to the value of a project in Africa. 
  • Special Litigation Committee of a Fortune 50 company in an internal investigation related to the Company’s handling of allegations of sexual harassment;
  • Global telecommunications company in an SEC/DOJ inquiry regarding alleged payments to government officials in various countries;
  • Various senior executives in connection with SEC/DOJ investigations into potential FCPA violations;
  • Large Asian company in connection with SEC investigation of potential FCPA violations;
  • Special committee of a large Chinese company in an independent review of allegations of fraud; and
  • Major mining consortium in South America in connection with the design and implementation of an enhanced anti-corruption program.

She is recognized as one of the “25 Most Influential Women in Securities Law” by Law360, and is consistently listed in the “Top 250 Women in Litigation” by Benchmark Litigation where market commentators describe her “huge place in the FCPA world”; “She was the leader of the SEC in the FCPA field and brings a wealth of experience to the table.” Cheryl was also recently named to Savoy Magazine’s “2018 Most Influential Black Lawyers” list. In addition, Cheryl was named to the “Enforcement 40” by the Securities Enforcement Forum, she is consistently recommended by The Legal 500 in white collar, and was named a National and Washington, D.C. “Litigation Star” by Euromoney's Benchmark Litigation in white collar.

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

 

 


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

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

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


Brian Whisler is Chair of the DC Litigation and Government Enforcement Practice Group, as well as a member of the North American Government Enforcement Steering Committee.  He is a member of Baker & McKenzie’s Compliance and Investigations, Dispute Resolution and Global Pharmaceuticals Practice Groups, and serves on the North American Healthcare Steering Committee.  Prior to joining Baker & McKenzie, Mr. Whisler was an Assistant U.S. Attorney for 15 years, beginning in the Western District of North Carolina and followed by the Eastern District of Virginia, where he served as the Criminal Chief Assistant US Attorney, managing the criminal trial practice of the Richmond office which handled cases ranging from white collar crime, violent crime, public corruption and terrorism.  He has extensive investigative and trial experience and has taught as an adjunct member of the University of Richmond School of Law, and an instructor at the National Advocacy Center, University of South Carolina.

Education:

  • J.D., George Mason University School of Law (1989)
  • B.A., Grove City College (1985)

Bar Admissions:

  • Virginia (1989)
  • North Carolina (1994)


Alexandra Wrage is the president of TRACE. She is also the editor of How to Pay a Bribe: Thinking Like a Criminal to Thwart Bribery Schemes, the author of Bribery and Extortion: Undermining Business, Governments and Security and the host of the training DVD Toxic Transactions: Bribery, Extortion and the High Price of Bad Business produced by NBC. Ms. Wrage has written three compliance guidebooks and is a guest blogger on the Huffington Post. She speaks frequently on topics of international law, innovative compliance initiatives and the hidden costs of corruption, and regularly authors articles appearing in the business and legal media, including a bi-weekly column for Corporate Counsel.
               
Ms. Wrage currently serves on the Independent Governance Committee (IGC) of the Fédération Internationale de Football Association (FIFA), football's governing body.  She has previously served as Chair of the Anti-Corruption Committee of the ABA's International Section and Chair of the International Legal Affairs Committee of the Association of Corporate Counsel.  She has participated in anti-bribery working groups with the OECD and the UN Global Compact. Ms. Wrage was named one of the "Canadians Changing the World" by the Toronto Globe and Mail in 2011 and one of Maryland's Top 100 Women and Most Admired CEOs for 2012 by the Daily Record.
               
Prior to founding TRACE, Ms. Wrage was international counsel at Northrop Grumman where she was responsible for managing and improving the company's compliance program, including policy revisions, training, monitoring and board briefings.  
               
Ms. Wrage, a Canadian, studied law at Kings College, Cambridge University. She lives now in Annapolis, Maryland, with her husband and two sons.


Alistaire Bambach has been an Assistant Regional Director and Chief Bankruptcy Counsel to the Division of Enforcement since 2001. She was previously a Senior Trial Counsel in the Division of Enforcement. Ms. Bambach obtained a B.S. in Industrial and Labor Relations from Cornell University in 1983 and a J.D. in 1986 from the University of Houston Law Center. From 1986-1987, she was a law clerk for the Hon. Carl O. Bue, Jr., United States District Judge, Southern District of Texas. From 1988-1994, Ms. Bambach was associated with the firm of Weil, Gotshal & Manges in New York.  Since 1995, Ms. Bambach has worked at the United States Securities and Exchange Commission. In her current position Ms. Bambach is counsel to the SEC's Enforcement Division on all bankruptcy and insolvency matters, and has oversight over the SEC's receivership program. Ms. Bambach is also responsible for investigating and litigating complex financial fraud cases which result in corporate insolvencies. These cases include Enron, WorldCom, Adelphia, Lehman, Madoff and MF Global. Ms. Bambach is a frequent lecturer on the SEC's practices and procedures and on the intersection of the federal securities laws and bankruptcy and insolvency law. In 2006, Ms. Bambach received the Stanley Sporkin Award.


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.


Chris Cummings is a partner in the Corporate Department and a member of the firm's Capital Markets and Securities and Canadian Practice Groups. Based in Toronto, he practices U.S. securities law with a particular emphasis on cross-border capital markets and mergers and acquisitions. He has worked on a broad range of public and private transactions for investment banks and companies in a number of industries, including oil and gas, mining, insurance, transportation, computer hardware and software development and telecommunications. Chris is a graduate of Vanderbilt University Law School and Duke University.


Mark Morrison is a partner in Blakes Litigation Group with a focus on anti-corruption compliance, white-collar crime defence, competition and commercial litigation. Mark regularly advises Canadian and multinational corporate clients on compliance with domestic and international anti-corruption legislation, undertakes internal anti-corruption audits and investigations, assists clients with anti-corruption due diligence during mergers and acquisitions and has successfully defended complex Criminal Code anti-corruption cases.  Mark has undertaken internal anti-corruption investigations and assisted companies in resolving anti-corruption issues arising from conduct in Africa, Central America, South America and Asia. Examples of Mark's experience defending corporate clients and individuals in white-collar crime cases include defences such as: numerous Criminal Code matters including charges alleging bribery of public officials and cross-border conspiracy charges; Competition Act charges of bid rigging and allegations of price fixing; Occupational Health & Safety charges; environmental charges; and matters before the Securities Commission. Mark has been recognized as one of Canada's leading Business Crime Defence lawyers in the International Who's Who of Business Crime Defence Lawyers.


Steven Tyrrell serves as co-chair of the firm's White Collar Defense & Investigations Group. His practice focuses on white collar criminal defense, regulatory enforcement matters, and internal investigations.

Mr. Tyrrell previously served as Chief of the U.S. Department of Justice's Fraud Section from 2006 through 2009. In that capacity, he led the investigation, prosecution, and coordination of a broad range of sophisticated economic crime matters and enforcement initiatives, including matters involving the Foreign Corrupt Practices Act, corporate, securities, commodities and investment fraud, health care fraud, procurement fraud, stimulus and rescue fraud, mortgage fraud, consumer fraud, and identity theft. He also played a key role advising Department leadership on white collar crime-related legislation, crime prevention, public education and the Department's Financial Fraud Enforcement Task Force.

Prior to Mr. Tyrrell's appointment as Chief of the Fraud Section in 2006, he served as Deputy Chief of the Counterterrorism Section of the Criminal Division, where he supervised a team of attorneys in connection with the investigation, prosecution, and coordination of a variety of international terrorism and terrorist financing matters. Mr. Tyrrell also led a number of high-profile national security investigations and trained federal prosecutors and agents on relevant national security statutes, policies and practices.

Mr. Tyrrell also served as an Assistant US Attorney in the US Attorney's Offices in the Southern District of Florida and the Northern District of New York. During his more than fifteen years as an Assistant US Attorney, Mr. Tyrrell investigated and prosecuted a variety of criminal cases, with an emphasis on white collar matters, including but not limited to securities fraud, health care fraud, government contract fraud, bank fraud, tax fraud, FDA fraud, and public corruption, as well as related money laundering and asset forfeiture work. He also was lead counsel for the United States in nearly forty criminal jury trials.

Early in his career, Mr. Tyrrell served as Law Clerk to the Honorable Thomas J. McAvoy, United States District Court Judge for the Northern District of New York.

Mr. Tyrrell is the recipient of the Attorney General's Award for Distinguished Service (2005), the Inspector General's Integrity Award, Department of Health and Human Services (1999), the Timothy J. Evans Memorial Award, U.S. Attorney's Office (S.D. Fla., 1998), and numerous citations and letters of commendation

Mr. Tyrrell is a recognized expert and frequent speaker on a host of white collar topics, including FCPA enforcement, securities fraud, corporate charging decisions, use of deferred and non-prosecution agreements, and monitors.


Thomas McCarthy, Jr. is a trusted advisor to clients engaged in global trade and operations in the areas of compliance, integrity and governance, including corporate governance, international internal investigations, and anti-bribery and World Bank integrity compliance, monitoring and antifraud mechanisms.

Practice & Background

Mr. McCarthy has extensive experience in national and international anti-bribery and anti-corruption compliance laws and standards, as well as World Bank integrity and sanctions regimes, and in conducting international internal investigations, and developing compliance programs to combat internal and external fraud for companies operating in the global marketplace, as well as in developing effective risk mitigation measures and voluntary disclosure programs. Prior to joining Akin Gump, he was a senior institutional integrity officer for the World Bank Group. In that role, he directed and conducted numerous international investigations and served as a member of the Special Litigation Unit, overseeing the planning, processing and prosecution of debarment proceedings before the World Bank Sanctions Board, as well as criminal referrals to national governments deriving from investigations.

Mr. McCarthy's experience includes internal investigations relating to procurement processes and allegations of fraud and corruption involving multimillion-dollar government contracts. In the course of his investigations, he has worked in close coordination with U.K., German and other European law enforcement authorities, as well as U.S. law enforcement authorities, including the Federal Bureau of Investigation (FBI), the Internal Revenue Service (IRS), the Securities and Exchange Commission (SEC), U.S. Attorneys' offices and the Department of Justice (DOJ). Internationally, he has worked on investigations arising in the United Kingdom, Germany, India, China, Indonesia, Cambodia, Thailand and Laos.

In addition, Mr. McCarthy has served as general counsel to health care companies, where he was responsible for ensuring full compliance with complex federal and state regulations, including False Claims Act, Stark I and II, antikickback and RICO, as well as compliance with Department of Health and Human Services Office of the Inspector General (OIG) preliminary and final voluntary disclosure programs and protocols.

Mr. McCarthy is a member of the International Bar Association.