Safwat

Adam Safwat

Partner
Co-Chair, White Collar Crime & Government Investigations Practice
Washington, DC

I represent companies and individuals before the DOJ, SEC, CFTC and CBP in domestic and international investigations.

Adam Safwat focuses on white collar criminal defense, government and Congressional investigations, corporate enforcement matters, and internal investigations. His practice is multi-faceted, and he has extensive experience advising clients involved in matters impacting public and private companies, including securities and accounting fraud, financial fraud, anti-money laundering enforcement, U.S. economic sanctions, enforcement matters related to Transnational Criminal Organizations (TCOs) and cartels operating in Latin America and Mexico, and Foreign Corrupt Practices Act (FCPA) enforcement.  Adam routinely counsels companies on managing international risk in their operations.  In addition, Adam has experience representing clients involved in matters relating to bribery of U.S. politicians and the Foreign Agent Registration Act (FARA). 

Clients seek Adam’s advice to guide them through high-stakes matters facing the federal government, including representing high profile individuals, companies and organizations in sensitive DOJ and Congressional investigations.    He has experience servicing clients in the energy, financial services and pharmaceutical sectors, among other industries.  In addition, he provides clients in a host of industries with extensive counseling on best practices for compliance programs, internal controls, and communication strategies involving high-risk issues.
 
Adam previously served as a deputy chief of the Fraud Section of the U.S. Department of Justice’s Criminal Division from 2012 to 2014, having also served as an assistant chief and a trial attorney from 2006 to 2012. During his time at the Fraud Section, Adam served on several complex securities fraud investigations of individuals and entities in the financial services industry, including matters involving alleged accounting fraud relating to complex derivative instruments and special purpose entities. Adam was a member of the government’s successful trial team in a case against five former reinsurance executives involving accounting and financial statement fraud and concluded a related corporate settlement with a major reinsurance company.  Adam also led significant FCPA investigations involving companies operating in the commodities, oil services, logistics, and defense industries. He coordinated a multi-jurisdictional investigation resulting in one of the largest FCPA corporate settlements.

While at the Fraud Section, Adam also routinely assisted senior Justice Department officials in responding to Congressional inquiries and preparing for testimony before Senate and House committees investigating the 2008 financial crisis and other issues.  

In addition to his case work, Adam worked on policy matters such as new criminal discovery initiatives within the Criminal Division and on proposed amendments to the U.S. Sentencing Guidelines relating to corporate accounting fraud and insider trading.

Prior to joining the Fraud Section, Adam spent four years as an assistant U.S. attorney in the U.S. Attorney's Office for the District of Delaware, where he conducted jury trials in general crimes cases and also concluded a number of successful white collar investigations in areas such as theft of trade secrets and tax fraud.
 

Education

  • Duke University School of Law, J.D., Order of the Coif (1994)
  • Duke University School of Law, LLM, International and Comparative Law (1994)
  • University of California, Berkeley, B.A., high honors (1990)
     

Bar and Court Admissions

BAR ADMISSIONS
  • District of Columbia
  • New York
  • California
COURT ADMISSIONS
  • Eastern District of New York
  • District of Columbia
  • United States District Court for the Southern District of New York

Experience

  • Represented an individual in a Congressional ethics investigation focused on corruption allegations against a member of Congress.
  • Represented a former Biden Administration official in federal lawsuits alleging civil rights violations due to the Biden Administration’s COVID vaccine policies.
  • Successfully obtained the de-listing of a Russian national who was affiliated with a major Russian financial institution from OFAC’s list of Specially Designated Nationals (the SDN list).
  • Routinely counsel national and international non-profit organizations on managing risk related to international partners and FARA compliance.
  • Represented a former public school procurement officer in a federal corruption trial in the U.S. District Court for the District of Columbia.
  • Counseling clients on potential claims and liabilities facing business partners in connection with IEEPA Tariff refunds.
  • Representing an energy importer before the U.S. Customs and Border Protection agency (CPB) in a matter relating to tariffs.
  • Representing a financial services firm in a Congressional investigation regarding ESG investing practices.
  • Counseling clients on Congressional and governmental investigations related to ESG, DEI and other issues involving federal disbursement programs.
  • Representing individuals in a high-profile Justice Department investigation regarding domestic bribery and allegations of violations of the Foreign Agent Registration Act.
  • Representing individuals charged by the Justice Department with criminal international sanctions evasion.
  • Counseled an energy company on mitigation of risks under U.S. economic sanctions implicating existing supply sourcing agreements.*
  • Advised a global business solutions provider on sanctions and federal contracting risks associated with grey-market channel resale activity.*
  • Conducted an internal investigation on behalf of and represented a global pharmaceutical company in a joint DOJ and SEC investigation of alleged FCPA violations in several countries in Eastern Europe, the Middle East, and Asia.*
  • Represented a global pharmaceutical company before the SEC in a global compliance review.*
  • Represented a global pharmaceutical company before the SEC in an investigation into revenue recognition practices.*
  • Represented a former senior executive of a major South Korean industrial firm in a DOJ and SEC investigation involving alleged FCPA violations arising from transactions in Brazil.*
  • Conducted a comprehensive review on behalf of a major financial services corporation of its HR and Compliance investigations functions.*
  • Represented a nonprofit organization as counsel in a federal investigation concerning the company’s conduct and practices in a federal contract selection process.*
  • Represented a large retail fund company regarding allegations of fund mismanagement in an offshore credit fund in India.*
  • Successfully defended a pharmaceutical company in a TRO hearing in federal court involving Lanham Act violations related to comparative safety claims.*
  • Conducted comprehensive anti-money laundering program compliance reviews of prospective debt issuers on behalf of a securities underwriter.*
  • Counseled a U.S. industrial firm on anti-corruption risks associated with a joint venture in Brazil.*
  • Provided FCPA advice to an aircraft leasing company in connection with a transaction involving a state airline.*
* - handled by Adam prior to joining Foley Hoag

PROFESSIONAL EXPERIENCE
  • U.S. Department of Justice, Criminal Division
    • Deputy Chief, Fraud Section (2012–2014)
    • Assistant Chief, Fraud Section (2008–2012)
    • Trial Attorney, Fraud Section (2006–2008)
  • Assistant U.S. Attorney, U.S. Attorney’s Office for the District of Delaware (2002–2006)

Publications

FinCEN Finalizes Rule Eliminating Beneficial Ownership Reporting Requirements for U.S. Companies and U.S. Persons Under the Corporate Transparency Act Page
Blog Post 09/02/2026
On August 11, 2026, FinCEN issued a final rule (“Final Rule” or the “Rule”) adopting, with certain limited changes, FinCEN’s March 26, 2025 interim final rule (“IFR”), which narrowed beneficial ownership information (“BOI”) reporting requirements under the Corporate Transparency Act (“CTA”).
Securities Enforcement Under Chairman Atkins Page
Blog Post 08/28/2026
A little more than halfway into the SEC’s first full year under the leadership of its Chairman, Paul Atkins, recent SEC actions give a glimmer into possible emerging trends in enforcement.
Trump Administration Increases Sanctions Pressure on Iran through “Operation Economic Outcast” Page
Blog Post 08/25/2026
The Trump Administration launched “Operation Economic Outcast” on Monday, August 24, 2026, expanding U.S. economic sanctions targeting additional sectors of Iran’s economy in an effort to weaken the Iranian regime and drive a wedge between Iran and the countries with which it has continued to trade.
OCC Proposes BSA/AML and Sanctions Compliance Standards for Permitted Payment Stablecoin Issuers Under the GENIUS Act Page
08/19/2026
On June 24, 2026, the Office of the Comptroller of the Currency (“OCC”), in coordination with the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) and the Office of Foreign Assets Control (“OFAC”), published a Notice of Proposed Rulemaking (“NPRM” or “Proposed Rule”).
DOJ Announces First FCPA Deferred Prosecution of 2026: Key Takeaways from Scoular’s $10 Million Resolution Page
Blog Post 07/21/2026
On July 17, 2025, DOJ announced that The Scoular Company, an agricultural supply chain company headquartered in Omaha, Nebraska, entered into a three-year DPA in connection with a criminal information filed in the Western District of Texas.
Modernizing BSA/AML Compliance: FinCEN’s Proposed Program Rule and Coordinated Federal Rulemakings Page
Blog Post 07/20/2026
FinCEN’s proposed program rule places the onus on financial institutions to understand their money laundering and terrorism financing risks and tailor their compliance programs accordingly.
Tightening the Vise: E.U. Continues Sanctions Pressure Against Russian Origin Oil Page
Blog Post 06/23/2026
The E.U.’s 21st sanctions package builds on previous sanctions against Russian crude oil implemented in the E.U.’s 20th sanctions package and signals an increasingly more restrictive regime than the U.S.’s sanctions program against Russian crude oil.
Sripetch v. SEC: The Supreme Court Holds That Disgorgement Does Not Require Proof of Investor Pecuniary Loss Page
Blog Post 06/09/2026
On June 4, 2026, the U.S. Supreme Court unanimously held that the SEC need not prove investors suffered actual financial losses before obtaining a disgorgement award.
Anticorruption Enforcement and the FCPA: 2026 Year in Preview  Page
Blog Post 01/27/2026
2025 saw fundamental shifts in Foreign Corrupt Practices Act (“FCPA”) enforcement priorities under the first year of the second Trump Administration.
Blog Series on Tariff Practices and Enforcement Page
Blog Series 06/03/2025
In light of the recent increases in U.S. tariffs, lawyers in Foley Hoag’s International Trade and National Security Practice recently took a look at high-risk tariff practices and potential enforcement consequences.

Other Publications

IN THE MEDIA
  • Quoted, "Obligations Linger Despite Freepoint’s Settlements With DOJ and CFTC," Anti-Corruption Report (August 2024)

Honors & Involvement

HONORS
  • The Legal 500, Dispute Resolution: Corporate Investigations & White Collar Criminal Defense (2015, 2019)
  • Global Investigations Review “Name to Know” in inaugural edition of the GIR 100 (2015)
INVOLVEMENT
  • American Bar Association            
  • International Bar Association

Other Events

  • “FCPA Enforcement & Compliance Insights for Importers and Exporters," Advanced Topics in Customs Compliance (ATCC) Conference (February 2025)
  • "FinTech Exits and Investable Businesses," FinTech University Series, Presenter (August 2023)
  • "Building an Investable Business – Preparing Your Company Now for Successful Exit/Acquisition and Outside Investment," Nelson Mullins Riley & Scarborough, Co-Speaker (April 2023)
  • "Foreign Corruption and Domestic Money Laundering: Traps for Professionals," Practising Law Institute, Speaker (May 2021)
  • "Cross-Border Investigations in China and Brazil, Global Investigations Review Live Sanctions," Export Control and National Security, Washington D.C., Moderator (October 2019)
  • "Defending Your Compliance Program to the Agencies," presented at the International Compliance & Anti-Corruption Conference, hosted by the Institute for U.S. Law and George Washington University, Washington, D.C., Speaker (March 2019)