Galen Kast

Partner

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Areas of Work

Independent & Internal Investigations, White-Collar Defense, Blockchain & Cryptocurrency, Financial Services

Overview

Galen Kast counsels companies and individuals in high-stakes government enforcement matters, internal investigations, and civil litigation. Additionally, he advises clients on corporate compliance and governance. He has experience advising clients across various industries including finance, investments, and trading; blockchain and cryptocurrency; securities; healthcare; automotive and transportation; energy; foods; dietary supplements; pharmaceuticals and medical devices; and startups and technology.

Galen regularly represents clients in matters before the US Department of Justice (DOJ), state attorneys general, the Securities and Exchange Commission (SEC), the Commodity Futures Trading Commission (CFTC), and other government agencies. His experience spans all phases of government enforcement, from pre-indictment investigations and negotiations with government agencies through trial and post-trial briefing. Galen has also conducted complex domestic and cross-border internal investigations in response to whistleblower complaints and internal corporate assessments.

Galen has substantial experience defending clients against a wide range of allegations by state and federal agencies, including accounting, securities, wire, and mail fraud, antitrust conspiracies, bribery, false claims, false statements, money laundering, obstruction, price gouging, tax evasion, adulteration, misbranding, and other business crimes.

He also advises clients on internal compliance programs and controls, from the initial development of compliance programs in early-stage startups to compliance program assessments and enhancements in Fortune 500 companies. Galen has designed and led large-scale corporate compliance reviews, and has served as the independent compliance consultant for prominent financial institutions, specifically in relation to the collection and retention of employee electronic communications.

Galen is active in Steptoe's pro bono program, and has represented clients in both housing and criminal matters.

District of Columbia

J.D., Georgetown University Law Center, 2016, magna cum laude; Editor in Chief, American Criminal Law Review, Annual Survey of White-Collar Crime
M.Ed., Marquette University, 2013, Education Policy and Leadership
B.A., Carleton College, 2011, magna cum laude, Psychology

Areas of Work

Representative Matters

Investigations, Compliance, & Litigation

Investigations

Representation of iFinex Inc., the owner of the Bitfinex cryptocurrency exchange, and Tether, the world's largest stablecoin issuer, in investigations by the CFTC and the New York Attorney General's Office; both investigations were resolved with settlements favorable to the company.
Representation of multiple former FTX executives in connection with investigations by the Department of Justice, Securities and Exchange Commission, and Commodity Futures Trading Commission.
Representation of Volkswagen AG in diesel emissions criminal case and related matters.
Representation of cryptocurrency companies in connection with investigations by the Securities and Exchange Commission.
Representation of cryptocurrency companies in connection with investigations by the Department of Justice.
Representation of prominent global financial company in investigations by the Department of Justice and Commodity Futures Trading Commission.
Representation of fuel retailer in state attorney general price-gouging investigation involving multiple fuel retailers operating in the Western United States. Developed a proposed resolution framework stemming from the preparation of an exhaustive "white paper" on price gouging regulations, which led to resolution featuring nominal settlement payments with prophylactic compliance measures.
Representation of transportation company in federal False Claims Act investigation by the Department of Justice.
Representation of energy services company in connection with internal audit committee investigation.
Representation of global healthcare company in multiple internal investigations.
Representation of executive of prominent global financial institution in connection with settlements with the Securities and Exchange Commission and the Commodity Futures Trading Commission regarding the collection and retention of employee electronic communications.
Representation of investment fund executives in connection with investigation by the Securities and Exchange Commission.
Representation of energy executive in federal fraud investigation. The government did not pursue charges.
Representation of pharmaceutical executive in misbranding investigation. The government did not pursue charges.
Representation of startup owner in federal fraud investigation by the Department of Justice. The government did not pursue charges.
Representation of executive at prominent accounting firm in connection with internal investigation.

Compliance

Representation of prominent cryptocurrency company regarding enhancements to internal compliance policies and controls.
Representation of nascent cryptocurrency exchange regarding the development of internal compliance policies and controls.
Representation of prominent global financial institution in connection with an internal compliance assessment of employee electronic communication policies and procedures.
Representation of multiple domestic financial institutions as independent compliance consultant in connection with settlements with the Securities and Exchange Commission and the Commodity Futures Trading Commission regarding the collection and retention of employee electronic communications.
Representation of prominent global financial institution as independent compliance consultant in connection with settlements with the Securities and Exchange Commission and the Commodity Futures Trading Commission regarding the collection and retention of employee electronic communications.

Litigation

Representation of insurance company in putative class action against 401(k) plan fiduciary asserting fiduciary breach claims. Case was dismissed on summary judgment.
Representation of company and individuals in connection with SEC complaint alleging the use of fraudulent invoices and false sales and revenue disclosures.
Representation of executives in antitrust class action trial.
Representation of cryptocurrency company in civil litigation and compliance matters.

Criminal Defense

Successfully secured a complete defense acquittal for former Autonomy CEO Mike Lynch in a 13-year US federal criminal securities and accounting fraud case. The case relates to HP's $11-billion acquisition of Autonomy in 2011.
Successfully defended scientist and former university lab director in a three-week federal criminal trial against a 22-count indictment alleging conspiracy, bank fraud, wire fraud, and theft/bribery concerning programs receiving federal funds with alleged losses exceeding $6 million.
Representation of businessman in criminal sanctions case resulting in rare post-trial dismissal with prejudice following discovery of evidence that prosecutors withheld exculpatory evidence and made misrepresentations to the court.
Representation of private security company owner indicted on charges of federal program bribery.
Representation of company indicted for alleged Klein conspiracy to impede an SEC disgorgement judgment, and alleged wire fraud in connection with corporate sales and revenue disclosures.
Representation of individual indicted for alleged mail fraud, tax evasion, and false statements.
Representation of medical devices company executive indicted for alleged fraud and FDCA violations.
Representation of dietary supplement company indicted for alleged FDCA violations, wire fraud, conspiracy, obstruction of justice, and money laundering.

Regulatory & Policy

Representation of cryptocurrency fund regarding corporate and regulatory matters.
Representation of early-stage cryptocurrency companies on legal, regulatory and policy matters.

Speaking Engagements

"The End of Regulation by Enforcement…But Not the End of Enforcement," The Digital Chamber, Virtual Panel, May 19, 2025
"Law and Regulation of Blockchain & FinTech," Harvard Law School Annual Blockchain, FinTech & the Law Conference, March 3, 2020