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Corporate Investigations & White Collar Defense

Contacts

William M. Sullivan, Jr.
Partner, Washington, DC
T: +1.202.663.8027
Aaron S. Dyer
Partner, Los Angeles
T: +1.213.488.7321
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Pillsbury’s formidable Corporate Investigations & White Collar Defense practice successfully represents U.S. and international clients in large-scale and cross-border government inquiries, sensitive internal investigations, high-stakes compliance matters, and both civil and criminal litigation.

Pillsbury’s Corporate Investigations & White Collar Defense lawyers are leaders in defending corporate clients and their officers, board members and executives in federal and state criminal and civil investigations and prosecutions, state Attorney General investigations, regulatory enforcement proceedings, and civil and criminal forfeiture proceedings

The Pillsbury team has strong leaders who have deep prosecutorial experience, which gives them a unique advantage in handling complex and sophisticated matters.
—client, Chambers USA

Additionally, we have extensive experience in advising on and assisting clients with:

  • U.S. Securities Law Investigations & Compliance
  • Anti-Corruption Compliance and Investigations (including U.S. Foreign Corrupt Practices Act (FCPA) and UK Bribery Act)
  • Cybersecurity & Data Privacy Investigations & Compliance
  • Anti-Money Laundering, Tax, Financial Fraud, Trade Secrets, and other Corporate Crime Investigations and Prosecutions
  • Whistleblower Allegations
  • Sanctions and International Trade Controls Investigations & Compliance
  • False Claims Act Defense
  • Criminal Antitrust Investigations
  • Civil RICO and Financial Fraud Actions
  • Employment Investigations
  • Regulatory Enforcement
  • Consumer Protection Investigations & Compliance

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Pillsbury’s well-known and credentialed Corporate Investigations & White Collar Practice comprises former prosecutors and other lawyers with significant government experience.

Leveraging their former prosecutorial and international experience, our Corporate Investigations & White Collar Defense team deftly steers clients through investigating allegations and responding to government inquiries and litigation, as well as collateral civil lawsuits.

We regularly handle cross-border investigations and parallel investigations from multiple agencies, coordinating with local counsel and forensic analysts and accountants as needed. Beyond defense work, we also provide strategic guidance on ways to avoid potential criminal liability, and help clients create, implement and audit corporate compliance programs.

Representative Experience

  • Successfully defended former Westinghouse Vice President Jeff Benjamin in obtaining a dismissal of a criminal indictment alleging serious charges, including conspiracy, wire fraud and securities violations, on the grounds that his constitutional rights were violated when the government presented its case to a per se-biased grand jury.
  • Serve as Special Counsel to the Special Committee of the Suffolk County Legislatures in the investigation of a large-scale ransomware attack. Conduct an extensive investigation into the 2021 cyberattack, the county's preparedness and the county's current cyber defense posture. This investigation includes forensic examinations, dozens of witness interviews, public hearings, and coordination with federal, state and local law enforcement agencies.
  • Achieved a significant victory on behalf of clients, the University of Kansas and head men's basketball coach Bill Self. Following a years-long investigation, the NCAA's Independent Resolution Panel concluded that allegations of severe NCAA rules violations against the university and its men's basketball program were without merit, and in regard to Coach Self, only a single, Level 3 violation was supported by the record, which afforded no additional penalties beyond those self-imposed by the university, which the IRP also accepted. 

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  • Global Anti-Corruption, FCPA and UK Bribery Act Compliance and Investigations
    • Represented Fortune 100 technology company in DOJ investigation into alleged FCPA violations in China.
    • Represented global financial institution in cross-border sanctions investigation conducted by DOJ, OFAC, Federal Reserve and state criminal and regulatory authorities.
    • Represented petroleum and natural gas engineering company in a high-profile parallel SEC/DOJ FCPA investigation, persuading both agencies to decline criminal and civil enforcement actions.
    • Represented senior Hong Kong-based bank executive in a DOJ and SEC criminal investigation relating to allegations of FCPA violations in China, resulting in no charges being brought.
    • Represented major life sciences corporations in various FCPA investigations involving China, India and Australia on grants, improper payments to doctors and kickbacks from distributors.
    • Represented China-based U.S. issuer in development of global FCPA and sanctions compliance program, including for high-risk mergers and acquisitions and in the compliance aspects of M&A transactions involving targets across Asia, Russia, Latin America and the Middle East, and conducted compliance diligence and deal structuring in connection with billions of dollars of M&A transactions.
    • Represented major U.S. aerospace company in connection with internal investigations of possible FCPA violations in China, Greece, Spain, Argentina, Saudi Arabia and Indonesia.
    • Represented global private equity firm in billions of dollars of portfolio company investments in Greater China, India, Indonesia, Japan, Korea, Malaysia, the Philippines and Vietnam, including the conducting of anti-corruption, sanctions, AML, export controls due diligence, the forensic testing of target company financial records, the drafting and negotiating of transaction agreements, and the development, implementation and oversight of post-close internal controls.
    • Represented multinational engineering services and consulting company in parallel investigations by DOJ and the World Bank involving allegations that former employees violated the FCPA.
    • Defended former top executive of Hungary’s largest telecommunications provider against allegations of DOJ/SEC FCPA violations and bribery of government and political officials to win business, shut out competition and gain regulatory benefits.
    • Represented Board of Directors of the Pennsylvania Public School Employees’ Retirement System (PSERS) in a parallel SEC/DOJ investigation regarding the accurate calculations of investment returns. While both the DOJ and SEC ultimately declined to pursue charges, the SEC did charge the PSERS outside investment advisor with errors leading to discrepancies in investment returns, which charges the advisor resolved by way of settlement. 
    • Represented U.S.-listed technology company in internal investigation relating to allegations of FCPA violations at overseas gaming affiliate.
    • Represented publicly traded industrial materials company in an internal investigation involving allegations of potential violations of the FCPA in Eastern Europe and the former Soviet Union.
    • Represented international engineering company in an internal investigation into allegations of bribery of Saudi Arabian officials in connection with the sale of wastewater treatment equipment.
    • Represented senior Hong Kong-based telecom executive in an HKICAC investigation relating to allegations of corruption.
    • Represented underwriters, U.S. issuers and HK issuers in connection with IPO-related compliance due diligence, as well as anti-corruption, sanctions and litigation-related disclosures in public filings.
    • Represented the audit committee of a U.S.-listed nutraceuticals company in SEC investigation of potential FCPA violations.
    • Represented American manufacturing conglomerate in multiple internal investigations over several years into potential FCPA violations in China, Taiwan and Hong Kong.
  • Anti-Money Laundering, Tax, Financial Fraud, Trade Secrets, and other Corporate Crime Investigations & Prosecutions
    • ­Represented senior executives of Wells Fargo in the false account and cross-selling investigations initiated by a number of government agencies, including the DOJ, SEC, OCC and FINRA. No charges, sanctions or fines were ever sought or obtained against any of our clients, nor were any pursued in related civil litigation.
    • Represent former CFO of a digital currency exchange in connection with investigations by the DOJ, the SEC and the New York State Attorney General’s Office.
    • Represented multiple Swiss banks in IRS- and DOJ-led program in which we conducted a comprehensive internal investigation at each bank to identify potential U.S. taxpayer accounts and possible U.S. tax law violations.
    • Successfully represented senior executive in a multibillion-pound investigation by the UK Insolvency Service (IS) of an international financial services group, which resulted in a declination of charges.
    • Represented U.S. private equity-backed portfolio company in a dispute over the potential enforcement of debt facilities, which included successfully obtaining injunctive relief.
    • Represented two major French banks and five U.S. government agencies, respectively, in cross-border OFAC sanctions investigations, one of which resulted in the largest ever sanctions-related settlement.
    • Represented high-net-worth individual in a multibillion-pound asset-tracing investigation which relates to an international banking fraud.
    • Represented high-net-worth individual in a multibillion-dollar cross-border cryptocurrency investigation by the DOJ and FBI.
    • Represented several senior executives in multimillion-pound cross-border bribery and money laundering investigations by the SFO of an international oil and gas group and an international energy services group.
    • Represented former Central American FIFA soccer officer in a widely publicized international DOJ investigation involving cross-border money laundering and fraud allegations related to World Cup soccer matches.
    • Represented major international financial institution in an investigation of alleged violations of Iran trade sanctions.
    • Represented major international financial institution in a money laundering investigation involving correspondent bank accounts of an offshore bank entity.
    • Represented major international financial institution in DOJ forfeiture action involving correspondent bank accounts.
    • Represented prominent multinational bank in parallel investigations of alleged terrorist financing and money laundering by the DOJ and Office of the Comptroller of the Currency.
    • Acted for a money/check processor in connection with a DOJ investigation of money laundering and online gambling.
    • Represented former employee of a money processor in connection with a DOJ investigation into international money laundering allegedly involving operations in Panama, the United States, the UK and India.
  • Criminal Antitrust Investigations
    • Represented major international electronics manufacturer in parallel criminal antitrust investigations by the DOJ, EU, Japan and Canada, as well as multidistrict litigation alleging an industry-wide cartel to fix prices of TFT-LCD panels.
    • Represented international financial institution in multiple criminal and civil antitrust investigations into municipal securities derivatives and in multidistrict litigation alleging several banks and their executives manipulated the bidding process.
    • Represented Japanese auto parts manufacturer and executives of another Japanese manufacturer in various probes into allegations of anti-competitive practices in the auto parts industry by regulators in both the U.S. and Europe.
    • Acted for a number of officers and directors of a Scandinavian mining company in a criminal price-fixing investigation into the rock crushing and screening equipment industry.
  • U.S. Securities Laws Investigations & Compliance
    • Represented hedge fund and its founder in SEC investigation regarding insider trading.
    • Represented executive in SEC investigation of digital currency platform.
    • Defended major corporation against shareholder securities fraud claims relating to alleged accounting fraud and represented the company and senior executives in parallel SEC investigation; SEC declined to bring enforcement action.
    • Represented major corporation in SEC and DOJ investigation regarding accounting issues; enforcement authorities declined to charge client.
    • Represented founder and CEO of tech company in connection with SEC investigation of alleged offering fraud.
  • False Claims Act Defense
    • Defended global fitting manufacturer in a qui tam action filed by a self-styled customs expert involving allegations of customs fraud. The case involved ground-breaking qui tam jurisdictional and customs issues.
    • Successfully represented Japanese trading company in federal and California False Claims Act cases involving the sale and distribution of allegedly bulletproof vests to law enforcement agencies funded with federal dollars.
    • In the first FCA case brought relating to risk adjustment reporting, defended a Florida-based Medicare Advantage Plan alleged to have falsely increased the severity of diagnoses to obtain higher payments.
    • Successfully defeated a state and federal FCA case alleging an office furniture manufacturer sold equipment to government entities at prices that were falsely claimed to be below the prices charged to non-government customers.
    • Defended major international transportation company against allegations Amtrak had been sold defective environmental systems. In a precedent-setting opinion, the District of Columbia Circuit Court of Appeals dismissed these claims.
    • Defended U.S. university in DOJ-led FCA investigation involving alleged failures to disclose foreign funding.

Practice Area Highlights

  • Best Lawyers Best Law Firms ranked Pillsbury’s Criminal Defense – White Collar practice a National Tier 1 firm.
  • Pillsbury is recognized as among the most feared law firms for litigation by BTI Consulting Group.
  • Chambers USA ranked Pillsbury among the leading firms for Litigation: White-Collar Crime & Government Investigations in California and New York.

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  • The Legal 500 U.S. ranked Pillsbury’s national White Collar Defense practice as among the nation’s top practices.
  • The American Lawyer named Pillsbury as among the elite law firms recognized for the “Global Dispute of the Year” in the area of Investigations for Swiss banks DOJ investigation and program representation.
  • In its weekly Litigator of the Week column, Law.com recognized a Pillsbury litigation team led by William Sullivan, Jr., for achieving a rare dismissal on the grounds of grand jury bias for former Westinghouse Electric Co. nuclear executive Jeffrey Benjamin.
  • Several Corporate Investigations & White Collar Defense partners recognized in the Lawdragon 500 Leading Litigators in America

Awards

2024 MOST FEARED FIRMS

BTI Consulting recognizes Pillsbury as one of the most feared law firms in litigation.

2025 Best Lawyers

193 lawyers recognized as leading practitioners

2024 Chambers USA Leading Firm

52 Pillsbury Practices and 92 Firm Lawyers

National Law Journal

Bill Sullivan recognized as White Collar, Regulatory & Compliance Trailblazer

2024 Legal 500 U.S. Guide

35 practices ranked among best in the U.S.

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