Healthcare & Life Sciences

• Representing several health care payers in connection with antitrust merger investigations by DOJ, state AG and state Divisions of Insurance.
• Representing a large public company in responding to federal healthcare False Claims Act investigation conducted jointly by US Attorney’s Offices in several districts across the country concerning potential federal health care program reimbursement fraud arising out of alleged sales, marketing and pricing practices, including practices related to discounts, credits, and acquisition cost or average sales price reporting.
• Defended health care company in federal False Claims Act litigation concerning allegations of violations of the Anti-Kickback Statute.
• Defended genetic testing company and negotiated settlement of whistleblower complaint in investigation initiated by OIG, Health & Human Services subpoena concerning potential False Claims Act violations.
• Represented company leadership and employees in Department of Justice criminal investigation into alleged federal health care fraud violations, including responding to subpoenas and preparing clients for interviews.

Securities, Financial Services and Investment Management

• Represented former Big 4 audit partner in obtaining lift of bar order previously issued by the SEC.
• Represented a multi-billion dollar pension fund in an internal investigation of alleged wrongdoing by fund management and others.
• Won the dismissal of all allegations in favor of a former executive at a financial services company in a SEC civil enforcement action in a case arising out of a complex group of transactions concerning the combination of certain defined-contribution plans. The win was affirmed by the First Circuit.
• Represented accounting firm, its partners and employees in connection with joint DOJ and SEC investigation concerning healthcare service company.

Technology

• Conducted internal investigation for a technology company concerning alleged kickbacks provided in violation of the FCPA in the Middle East.
• Led internal investigation concerning potential export control violation at scientific device company with a foreign parent company, advised on compliance improvements and drafted voluntary self-disclosure to government, with successful result of no government action.
• Conducted FCPA due diligence for a Fortune 500 information technology company in connection with a proposed acquisition.
• Advised the U.S.-based board member of a global high technology company regarding an internal investigation and external reporting of alleged corrupt activities by former executives.

International Business

• Served as cross-border compliance counsel to U.S. medical device company; advised on compliance with trade sanctions and export controls, including in connection with company’s partnerships and dealings with manufacturers, distributors and other entities in Asia and Europe.
• Assisted a European Telecommunications group and two major French defense companies in establishing their economic sanctions and export control compliance systems, encompassing risk assessment, policy creation, license applications, training, and legal advisory services on compliance with European and U.S. regulations.
• Assisted a major Global energy company and a major French engineering company in defining and implementing their economic sanctions and export control compliance systems, including guidance related to regulatory compliance for various operations, and other internal compliance practices and procedures.
• Assisted a major French public financial institution in launching an export credit offer for French exports to Iran, encompassing comprehensive sanctions compliance, risk analysis, international negotiations, and operational implementation, including partner selection and ongoing liaison with government authorities.

Anti-Corruption

• Represented global manufacturer in the defense industry in federal investigation into potential kickbacks involving head of international sales.
• Conducted internal investigations and pursued related civil fraud litigation concerning allegations of corruption involving the procurement subsidiaries of a global oil and gas company.
• Conducted FCPA due diligence for a large oil and gas company in connection with a proposed acquisition.
• Conducted an internal investigation of alleged kickbacks and gratuities to senior company executives for an international manufacturer, including pursuit of civil RICO and fraud actions against the executives and contractors involved.
• Represented the CEO of a large financial institution in criminal and regulatory investigations concerning anti-money laundering compliance.
• Represented multiple corporate executives of a large European pharmaceutical company in connection with a DOJ/SEC FCPA investigation involving activities in Eastern Europe and Africa.
• Advised leading anti-corruption non-governmental organization with respect to proposed U.S. anti-corruption and anti-money laundering legislation and rule-making.

Education & Research Institutions

• Conducting internal investigation for a public university concerning compliance with research misconduct investigation policies and procedures and the unauthorized disclosure of confidential documents.
• Represented university medical center in internal investigation regarding university-affiliated program’s compliance with federal and state regulations.
• Advise university clients regarding Title VI compliance issues, including international and regulatory investigations, mitigation measures, policy development, and trainings for students, faculty, staff, and administrators.
• Represented higher education client in highly publicized civil litigation related to a prominent university professor.

Congressional Investigations

• Counseled numerous leading biopharmaceutical companies during congressional inquiries regarding prescription drug pricing strategies in the United States.
• Counseled a leading genetic testing company with regards to a House investigation of marketing and claims for direct-to-consumer genetic testing.
• Represented former chief finacial officer of major national sports team in congressional and other investigation.
• Represented multinational technology and pharmaceutical companies in responses to congressional inquiries concerning international tax matters, and prepared executives for potential testimony.

Foreign Agents Registration Act (FARA)

• Representing individual witnesses in connection with a U.S. Department of Justice criminal FARA investigation into the activities of a non-governmental organization receiving grant funding from foreign sources, including preparing witnesses for interviews and responding to government inquiries.
• Represented the chief executive of a major U.S. exporter in connection with internal and federal investigations of alleged violations of the Foreign Corrupt Practices Act in India.*
• Represented an individual in connection with a criminal investigation by the U.S. Department of Justice concerning alleged violations of the Foreign Agents Registration Act.*
• Advised a sovereign wealth fund regarding FARA registration obligations and filing requirements.*
• Advised a non-U.S. investment fund on FARA filing obligations and compliance with registration requirements.*
• Advised various non-U.S. financial institutions on FARA filing obligations and related compliance considerations.*
• Advised numerous non-U.S. companies on FARA registration requirements and filing obligations.*
• Counseled clients on whether their activities require registration under the Foreign Agents Registration Act, including advising on FARA compliance obligations, preparing and submitting FARA registrations, and handling matters involving criminal jury trials alleging FARA violations.*

* Denotes matter handled by Foley Hoag LLP attorney prior to joining the firm