With discreet counsel on the limits of discretion, [Pillsbury] lawyers ushered in a new era of cooperation between a tight-lipped industry and a government whose zeal knows no borders.
The American Lawyer's Global Legal Awards, Tax Investigations

Fabio Leonardi concentrates on white collar criminal defense, including criminal prosecutions and grand jury investigations, as well as corporate internal investigations, agency enforcement actions, regulatory investigations, complex civil litigation and compliance counseling.

Selected as a Washington, DC Super Lawyers “Rising Star” in White Collar Crime Defense and a member of the group ranked by Global Investigations Review for “Cross-Border Investigations” and by The American Lawyer for “Global Dispute of the Year,” Fabio has substantial courtroom litigation and investigative experience representing public and private companies as well as key executives and officials in criminal prosecutions, civil enforcement actions, global regulatory inquiries, grand jury criminal investigations, corporate internal investigations and complex civil litigation with a particular focus on the Foreign Corrupt Practices Act (FCPA), cybercrime, securities enforcement, insider trading, money laundering, U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) economic sanctions evasion, embezzlement, bribery, civil antitrust, criminal cartels/price-fixing, tax crimes, criminal sports investigations, government procurement and bank fraud, racketeering (RICO), False Claims Act (FCA), illegal campaign contributions, and U.S. Department of Commerce’s export controls violations.

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In his zealous representation of companies and individuals, Fabio has been uniquely successful in persuading government authorities to decline to pursue criminal prosecutions or other regulatory enforcement actions in a broad range of criminal and agency enforcement matters. Consequently, because a large number of his most successful matters have not resulted in the filing of public charges, they remain confidential.

Fabio has honed his courtroom skills in both federal and state courts, where he has represented clients in criminal prosecutions and complex civil litigation matters. Additionally, he works closely with both federal and state public defender’s offices, where he defends indigent individuals in criminal prosecutions and government investigations.

Fabio frequently prepares and advises on corporate compliance policies and procedures, including on ethics, anti-corruption (FCPA, Travel Act and U.K. Bribery Act), anti-money laundering and anti-human trafficking. Fabio spearheaded the firm’s Anti-Human Trafficking Litigation & Compliance group, one of the country’s first legal practices dedicated to advising businesses on anti-human trafficking compliance, anti-human trafficking litigation and corporate liability for human trafficking. As the Co-Chair of American Bar Association’s (ABA) Criminal Justice Committee as well as the ABA Criminal Justice Section’s Liaison, Fabio is often sought by the national media for analysis and comment regarding important criminal and regulatory enforcement matters. He has published numerous legal articles on a broad range of criminal and regulatory issues and is a frequent speaker on white collar criminal defense, enforcement actions, compliance and corporate liability for human trafficking.

Early in his career, Fabio served in regulatory enforcement at the U.S. Securities and Exchange Commission. As a member of the SEC's Division of Enforcement, he investigated technology companies and advised on a major SEC accounting fraud enforcement action that ultimately led to a $100 million settlement.

Fabio currently teaches tax crimes, government investigations and criminal prosecution as an Adjunct Professor of Law at Georgetown University Law Center, where he is also a board member of Georgetown Law’s Recent Alumni Advisory Council, a J.D. admission alumni interviewer and a mentor to current law students. Fabio further serves on the firm's Pro Bono Committee as well as its Attorney Recruiting Committee and is a past member of the firm’s Attorney Development Committee.

Representative Experience

In a historic representation, defended the president of a non-profit organization in the State of Maryland’s first ever criminal prosecution under its charitable soliciation laws; successfully persuaded prosecutors to resolve charges without any imprisonment or supervision.


Represented several Swiss financial institutions in DOJ and IRS probes into offshore accounts held by American depositors; negotiated the second smallest fine out of all the substantially capitalized banks participating in DOJ’s high-profile tax offshore program for Swiss banks.


Uniquely experienced in major sports criminal investigations, having defended a FIFA soccer official charged as part of DOJ’s worldwide bribery investigation related to FIFA’s World Cup Tournament, and having represented a prominent NCAA men’s basketball college program in the widely-reported DOJ’s criminal bribery investigation related to college sponsorship contracts.

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Foreign Corrupt Practices Act Investigations and Litigation

  • Represented employee of international drug manufacturer in a parallel DOJ/SEC investigation involving allegations of bribery in Ukraine and Russia.
  • Defended president of transportation company in DOJ criminal prosecution involving allegations of bribery in Russia.
  • Represented senior executive of multinational retail company in DOJ/SEC investigation related to alleged bribery of government officials in Mexico.
  • Defended a former executive of a Hungarian telecommunications company in a SEC civil enforcement action involving allegations of bribery of government officials in Macedonia and Montenegro.
  • Conducted internal investigation of U.S. subsidiary of Japanese heavy equipment manufacturer for potential FCPA violations in Mexico.
  • Advised U.S. pension fund on potential FCPA liability in connection with major cross-border portfolio acquisition.
  • Prepared and implemented corporate FCPA compliance programs for U.S. and foreign companies engaged in various industries.

Criminal Sports Investigations and Litigation

  • Defended FIFA soccer official and former president of Central American soccer federation in historic DOJ criminal prosecution involving allegations of RICO, money laundering and bribery related to the sale of TV and media marketing rights in connection with FIFA’s World Cup Tournament.
  • Represented prominent NCAA men’s basketball college program in DOJ criminal bribery investigation and indictments related to college sponsorship contracts for student-athletes.

Office of Foreign Assets Control and Export Controls Investigations

  • Represented industrial tool manufacturer in OFAC enforcement investigation of Iran-related sanctions violations.
  • Conducted internal investigation for potential violations of OFAC’s Syria-related sanctions.
  • Represented shipping company in civil asset forfeiture litigation related to DOJ investigation of potential OFAC sanctions evasion and international money laundering in Syria.
  • Represented U.S. bank in OFAC sanctions violations investigation related to Iran.
  • Represented aerospace company in DOJ and Department of Commerce investigation for alleged export controls violations in China.
  • Represented technology company in voluntary disclosure for potential OFAC sanctions violations in South America.
  • Represented energy company in OFAC investigation for potential violations of Venezuela-related sanctions.

Criminal Antitrust Cartel Investigations and Litigation

  • Represented a former senior executive of an international airline in DOJ criminal prosecution involving allegation of price-fixing activities with respect to air cargo rates related to international air shipments.
  • Represented a senior executive of a U.S. company in a DOJ criminal cartel investigation of the home building products industry.

Securities Enforcement Investigations and Litigation

  • Represented former chairman of multinational company in SEC investigation involving allegations of accounting fraud.
  • Represented former chief financial officer of U.S. manufacturing company in SEC investigation for potential securities violations.
  • Represented senior officer of national financial institution in parallel SEC/DOJ and bank regulatory investigations involving allegations of securities fraud.
  • Represented senior executive of electric company in SEC investigation of alleged accounting fraud.
  • Represented former senior executive of energy company in SEC investigation involving allegations of securities and accounting fraud.
  • Represented chief financial officer of hydraulic system manufacturer in SEC investigation involving allegations of insider trading.
  • Represented U.S. manufacturer in SEC investigation of alleged securities violations.
  • Represented private investment company in SEC investigation involving allegations of insider trading.
  • Represented chief executive officer of venture capital firm in SEC investigation of alleged insider trading.

Tax Crimes 

  • Represented Swiss financial institution in connection with DOJ/IRS investigation involving allegations of tax evasion.
  • Defended dual-national businessman in DOJ criminal tax prosecution.
  • Represented subsidiary of Japanese bank in DOJ investigation involving allegations of tax evasion.
  • Represented subsidiary of German financial institution in DOJ/IRS investigation of alleged tax crimes.
  • Represented century-old Swiss bank in DOJ/IRS investigation involving allegations of tax evasion.

Cybercrime

  • Defended U.S. malware developer charged as part of international DOJ cybercrime investigation leading to the extradition of hackers from Russia and Latvia.
  • Represented U.K.-based crypto-currency exchange in DOJ criminal investigation.

Other Criminal Defense, Regulatory Enforcement and Civil Litigation Matters

  • Defended doctor and senior executives of U.S. healthcare organization in Federal Election Commission (FEC) investigation involving alleged violations of federal election campaign laws.
  • Defended regional executive of national financial institution in DOJ criminal prosecution involving allegations of bank fraud and conspiracy in connection with residential housing mortgage loans.
  • Defended president of non-profit organization charged with embezzlement, deceptive practices and fraud.
  • Represented a sovereign nation in connection with asset recovery and evaluation of international criminal violations as well as related interactions with U.S. and foreign law enforcement representatives.
  • Represented sovereign investment fund in international asset tracing and recovery as well as cross-border civil fraud litigation.

Anti-Human Trafficking Litigation and Compliance

  • Represented public company in first-of-its-kind anti-human trafficking litigation involving allegations of corporate liability within the U.S. hospitality industry.
  • Prepared anti-human trafficking compliance policies and procedures for U.S. businesses.
  • Advised on anti-human trafficking compliance and potential third-party corporate civil and criminal liability.
  • Developed major initiative analyzing civil liability and damages in civil anti-human trafficking litigation.

Professional Highlights

Washington, DC Super Lawyers “Rising Star” in White Collar Crime (2017-2018)


District of Columbia Courts, Capital Pro Bono High Honor Roll (2013, 2015-2017)


Columbian Lawyers Association, First Judicial Department Award (2008)

 

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Associations

  • Co-Chair, Criminal Justice Committee, American Bar Association; Liaison, Criminal Justice Section, American Bar Association
  • Faculty Member, Georgetown University Law Center
  • Board Member, Georgetown University Law Center’s Recent Alumni Advisory Council

External Publications

  • “Human Trafficking Raises Corporate Liability Concerns for the Hospitality Industry,” Real Estate Finance Journal, 2018
  • SEC Power to Recoup Illegal Profits Curbed by U.S. Supreme Court, Ebix (quote), 2017
  • Tackling the Heart of the Problem: Prosecuting Medically Unnecessary Stent Procedures, ABA Criminal Justice Magazine, 2017
  • Tax Enforcement in the Caribbean: Strategies for Financial Institutions and Asset Managers, Cayman Financial Review, 2016
  • False Claims Act Penalties to Double, Medical Economics (quote), 2016
  • New SEC Payment Disclosure Rules Raise FCPA Concerns for Energy Companies, Corporate Compliance Insights, 2016
  • The New Frontier for Bank Secrecy Act Prosecutions: Trade-Based Money Laundering, Law360 - White Collar, 2016
  • FCPA Pilot Program Formalizes Rewards but Relies on Discretionary Implementation, General Counsel News, 2016
  • Supreme Court Takes Broad View of False Claims Act: Watch Your Non-CMS Compliance, DecisionHealth (quote), 2016

Presentations/Speaking Engagements

  • American Bar Association, March 29, 2018, “Corporate Liability from Criminal Human Trafficking Prosecutions”
  • Georgetown University Law Center, March 8, 2018, “Current Issues in White Collar Crime”
  • American Bar Association, January 22, 2018, “Criminal Law for Business Lawyers”
  • Georgetown University Law Center, January 11, 2018, “Internal Investigation Simulation: Evaluating Corporate Corruption”
  • American Bar Association, Rule of Law Initiative, October 29, 2017, “U.S. Anti-Corruption and Anti-Money Laundering Law”
  • Pillsbury’s 2016 CLE Marathon – Virginia, September 27, 2016, “Follow the Money: The Evolution of the Panama Papers”
  • Georgetown University Law Center, January 13, 2016, “Anti-Corruption and International M&A”
  • Pillsbury’s CLE Presentation, April 14, 2015, “Addressing the Tax Challenges of the Digital Economy”

Education

  • LL.M., Georgetown University Law Center, 2011

    J.D., The George Washington University Law School, 2010

    B.A., University of Padua (Italy), 2007

    University of Michigan, 2006

Admissions

  • New York

    District of Columbia

    Florida

Courts

  • U.S. District Court for the District of Columbia

    U.S. District Court for the District of Maryland

    U.S. District Court for the Southern District of Florida

    U.S. Tax Court

Clerkships

  • Judicial Intern to the Hon. Reggie B. Walton, U.S. District Court for the District of Columbia

Languages

  • Italian