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Litigation, Investigations & Advisory

White Collar & Investigations

Strategic guidance through regulatory enforcement and corporate investigations

Top companies and senior executives rely on Ashurst Perkins Coie to navigate high-stakes investigations, regulatory enforcement actions, and related disputes and litigation.

Our global team of professionals have obtained outstanding results in sensitive investigations and regulatory enforcement matters about all forms of corporate and employee misconduct, including declinations with no charge, reversals on appeal, nonprosecution agreements, and deferred prosecution agreements. Many of our best outcomes remain confidential because they resulted in no public disclosure.

Our lawyers regularly handle matters before criminal and regulatory enforcement authorities around the globe, including the U.S. Department of Justice, SEC, the U.K. Financial Conduct Authority, the Serious Fraud Office, the Commodity Futures Trading Commission, Office of Foreign Asset Control, Federal Reserve, FTC, IRS, Financial Industry Regulatory Authority (FINRA), state attorneys general, and district attorneys. Our courtroom wins have spanned trial and appellate courts around the world.

Strategic counsel beyond the investigation

We know that an investigation is just one part of a broader picture. Our team provides incisive advice considering all relevant legal, reputational, commercial, and disciplinary issues and consequences.

Guiding clients through regulatory scrutiny

Our team frequently deals with regulators and enforcement agencies across the globe on a wide range of complex investigations and enforcement activity, enabling us to help clients navigate regulatory investigations and to mitigate and manage risks and outcomes.

Coordinated, rapid response across jurisdictions

Where an investigation crosses borders, we provide a coordinated, global response with a team of multilingual investigators across various jurisdictions. We regularly assemble experienced teams at short notice to respond to your urgent needs and can provide ongoing support with triaging and managing investigations at scale.

Remediation and improving compliance

We work closely with you to execute remediation efforts and identify trends that may require action or offer opportunities to improve internal systems and controls.

How we can help

  • Regulatory investigations

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  • Securities and commodities enforcement

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  • Anti-bribery and corruption

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  • Economic sanctions

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  • Royal commission and commissions of inquiry

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  • Monitorships and independent compliance consultancies

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  • Fraud investigations

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  • Cartels and antitrust investigations

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  • Market and sector investigations

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  • Cybercrime investigations

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  • Environmental compliance and enforcement

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  • Anti-money laundering

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  • False Claims Act (FCA)

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Professional experience

  • Conducted internal investigation for U.S. auto manufacturer related to potential consumer protection violations and negotiated resolution with state and federal authorities. 
  • Conducted internal investigation for food manufacturer related to potential federal and state consumer protection litigation. 
  • Investigate instances of potential employee misconduct for Fortune 100 technology manufacturer, coordinate forensic accounting analysis, and provide counsel regarding internal controls and remediation. 
  • Represented former CEO of global financial services company in a matter involving claims of market manipulation by the DOJ and Commodity Futures Training Commission. 
  • Represented numerous individuals and entities in various SEC insider trading investigations and obtained criminal declinations and/or “no admit, no deny” resolutions. 
  • Represented numerous entities in cryptocurrency investigations conducted by state and federal agencies, including 12 SEC investigations relating to whether entities raised funds through an unregistered public offering, or acted as unregistered broker-dealers or investment companies.
  • Represented Fortune 100 company in DOJ and SEC investigations of alleged violations of the FCPA in multiple countries throughout the world. 
  • Conducted multiple internal investigations for Fortune 500 companies on FCPA, Travel Act, and bribery/corruption issues, and conducted FCPA compliance training for multiple multinational companies. 
  • Representing a leading South American sports production company in the DOJ’s FIFA investigation and prosecution, successfully securing and completing the first corporate deferred prosecution agreement in the case. 
  • Drafted and oversaw the implementation of an anti-corruption compliance program for an Africa-based construction company sanctioned by the World Bank for engaging in fraudulent business practices. Our client was released from sanctions at the earliest available release date. 
  • Engaged as an independent compliance consultant for a multinational financial institution in order to conduct an independent end-to-end trade surveillance program review in connection with settlements with multiple financial regulators including the Commodity Futures Trading Commission, the Office of the Comptroller of the Currency, and the Federal Reserve. 
  • Served as a lead counsel for an FCPA monitor appointed by the DOJ and SEC, to oversee, evaluate, and test the anti-corruption compliance program of a multinational company, pursuant to the terms of a deferred prosecution agreement. 
  • United States ex rel. Holmes v. Huntington Ingalls Incorporated and Northrop Grumman Corporation. Secured a significant victory for Huntington Ingalls Industries and Northrop Grumman Corporation when a Mississippi federal judge dismissed a $2.5 billion False Claims Act suit against our clients and disqualified the relator.
  • United States ex rel. DeKort v. Northrop Grumman Shipbuilding, Inc. Successfully defended Northrop Grumman against claims that it violated the False Claims Act case in connection with the U.S. Coast Guard's Deepwater Program. The court granted Northrop Grumman's motion for summary judgment and dismissed relator's claim seeking $720 million in damages in connection with eight, 123-foot patrol vessels delivered to the U.S. Coast Guard.
  • United States ex rel. Erickson v. University of Washington Physicians. Defended a high-profile Medicare fraud case involving teaching physician services provided to Medicare and Medicaid beneficiaries.
  • United States ex rel. Grayson v. Genoa Healthcare. Defeated Medicare fraud and kickback allegations against a national chain of specialty pharmacies through waiver of co-payments and related allegations.
  • United States ex rel. Prather v. AT&T Inc. Represented Sprint Nextel Corporation and Qwest Communications International in a qui tam lawsuit related to charges for wiretaps and other surveillance services.
  • United States v. MD Spine Solutions LLC, D/B/A MD Labs Inc. et al. Successfully resolved an investigation led by the Office of the U.S. Attorney for the District of Massachusetts in parallel with numerous state attorneys general for alleged violations of the False Claims Act and the Anti-Kickback Statute based on a novel theory involving the reporting of test results for drug tests. The U.S. Department of Health and Human Services and the Centers for Medicare and Medicaid Services were also involved, as was a qui tam.
  • United States ex rel. Johnson et al. v. Therakos, Inc. et al. Successfully represented the client, the private equity owners of a medical device company, in a False Claims Act investigation involving the Office of the U.S. Attorney for the Eastern District of Pennsylvania and numerous state attorneys general alleging off-label promotion. The matter settled favorably at a small fraction of the amount initially demanded by the government.
  • United States ex rel. Zemplenyi v. Group Health Cooperative. Successfully defended Medicare fraud and whistleblower retaliation claims brought by a staff ophthalmologist against a leading health maintenance organization related to allegedly unnecessary cataract surgeries.
  • Represented Google in negotiating a nonprosecution agreement with the District of Rhode Island related to Canadian online pharmacy ads.
  • Conducted an internal investigation for a major university into potential false claims violations relating to federal grant funding.
  • Successfully represented the family trusts that held the value of one of the world’s largest privately held medical device manufacturers in the settlement of an investigation led by the Office of the U.S. Attorney for the District of Massachusetts that involved allegations of false claims based on kickbacks and improper marketing.
  • Successfully represented a prime contractor in an investigation led by the Office of the U.S. Attorney for the Eastern District of Virginia relating to false claims by a subcontractor, resulting in no liability for our client.
  • Represented a government contractor in an investigation conducted by an agency Office of Inspector General.
  • Represented a defense contractor in an internal investigation regarding False Claims Act issues.
  • Represented a healthcare device manufacturer in a government False Claims Act investigation.
  • Advised government contractor regarding disclosure and reporting obligations, including in connection with the False Claims Act.
  • Advising public companies on matters concerning supply chains (e.g., conflict minerals, anti-slavery reporting), safety, marketing, and environment.
  • Counseled transnational company in a federal class-action lawsuit alleging the company’s anti-trafficking disclosures misled consumers.
  • Represented (and represent) high-profile clients in multicontinent investigations and DOJ and SEC disclosures. Routinely collaborate with the firm’s dedicated Foreign Corrupt Practices Act and Anti-Corruption practice.
  • Prepared California Transparency in Supply Chains Act and U.K. Modern Slavery Act disclosure statements for dozens of U.S. and foreign companies in a cross-section of industries.
  • Routinely conduct anti-trafficking and anti-corruption investigations around the globe, including in Botswana, Brazil, China, Ethiopia, Ghana, Guinea, India, Indonesia, Kazakhstan, Liberia, Peru, Russia, Tanzania, Ukraine, and Uzbekistan.
  • Represented and counseled individuals facing simultaneous actions by multiple regulators, including the SEC, Commodity Futures Trading Commission, Federal Reserve, IRS, Financial Industry Regulatory Authority, state securities regulators, and various state prosecutors. 
  • Represented an international financial institution in connection with the LIBOR rate-rigging investigation conducted by DOJ, False Claims Act, Serious Fraud Office, and the Commodity Futures Trading Commission. 
  • Represent numerous entities in cryptocurrency investigations being conducted by state and federal agencies, including the SEC. Handled 12 SEC investigations relating to whether various entities raised funds through an unregistered public offering, and whether they acted as unregistered broker-dealers or investment companies. 
  • Obtained a $14.8 million jury verdict on behalf of Ameritox Ltd. in unfair competition case in federal court in Tampa. 

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