White-Collar Defense

Steptoe aggressively defends individuals in government and internal investigations, criminal trials, sentencings, appeals, parallel civil and administrative proceedings, and civil enforcement proceedings throughout the United States and abroad. We have experience in all areas of white-collar criminal enforcement, including securities and commodities fraud, wire fraud, bank fraud, public corruption, Foreign Corrupt Practices Act (FCPA), healthcare fraud, US Food and Drug Administration violations, antitrust, tax evasion, false claims, export controls and sanctions, environmental violations, perjury and false statements, obstruction, theft of trade secrets, and money laundering. We are also widely known as the go-to firm for enforcement matters involving cryptocurrencies and other digital assets.

Our notable recent individual representations include:

• Ali Sadr Hashemi Nejad. Steptoe obtained a rare post-trial dismissal with prejudice for businessman Ali Sadr, in a criminal Iran sanctions case tried in the Southern District of New York, after uncovering evidence that prosecutors withheld exculpatory evidence and made misrepresentations to the Court. Sadr was accused of violating the Iran sanctions regime in connection with a $475 million contract between a private Iranian company controlled by Sadr's father and a Venezuelan state-owned company to build low-income housing in Venezuela.
• Meng Wanzhou. Steptoe negotiated a favorable deferred prosecution agreement for the CFO of a major multinational telecommunications equipment company charged with wire fraud and bank fraud in a pending federal criminal case in the Eastern District of New York.
• Richard Ireland. Steptoe obtained a Rule 29 judgment of acquittal on all counts for Dick Ireland, a Philadelphia businessman accused in a "pay to play" case of bribing former Pennsylvania State Treasurer Rob McCord to obtain asset manager contracts. Despite McCord's guilty plea and cooperation, and dozens of hours of undercover recordings, the judge acquitted Ireland at the close of the government's case, commending Steptoe's performance as "some of the best trial work we have ever had the privilege to see in this or any courtroom."
• David Rainey. Steptoe secured an acquittal for David Rainey, the highest ranking BP executive charged in connection with the Deepwater Horizon oil spill, on a false statements charge tried in New Orleans, Louisiana. After the jury returned its not guilty verdict following two hours of deliberations, the judge stated on the public record that he "agreed with the verdict" and believed it was "a correct verdict based on the evidence." The acquittal followed the court's dismissal, on the first day of trial, of a related obstruction of Congress charge, after extensive pre-trial litigation in which the Steptoe defense team successfully argued that selective invocation of the Speech or Debate Clause privilege by congressional witnesses interfered with Mr. Rainey's right to present a defense.
• Andrew McCabe. Steptoe obtained a declination to prosecute the former Deputy Director and Acting Director of the FBI from the US Attorney's Office after a two-year long investigation. During the investigation, President Trump repeatedly and publicly urged the government to charge Mr. McCabe criminally.
• MingQing Xiao. Steptoe obtained an acquittal on wire fraud and false statement charges arising from a federal research grant proposal on behalf of a tenured Chinese-American applied mathematics professor at Southern Illinois University - Carbondale. Steptoe successfully argued for a sentence of probation on the remaining tax-related charges.
• William Facteau. Steptoe obtained an acquittal for ex-Acclarent CEO William Facteau of felony fraud charges brought by the government. The jury unanimously acquitted the defendant of all 14 felony charges: one count of conspiracy, three counts of wire fraud, and 10 counts of felony adulteration and misbranding.
• FTX Executives. Steptoe represents multiple former executives of FTX in a DOJ/SEC/CFTC investigation.

Steptoe has represented some of the largest public and private companies in the world in major government investigations. Through decades of experience, Steptoe has earned a global reputation for its representation of boards, audit committees, special committees, companies, and other institutions in government investigations and enforcement proceedings involving the DOJ, the Securities and Exchange Commission (SEC), the Commodity Futures Trading Commission (CFTC), Federal Bureau of Investigation (FBI), the Department of Homeland Security (DHS), the Internal Revenue Service (IRS), the Federal Trade Commission (FTC), the Federal Energy Regulatory Commission (FERC), the Department of Treasury's Office of Foreign Assets Control (OFAC), the Department of State’s Directorate of Defense Trade Controls (DDTC), the Department of Commerce's Bureau of Industry and Security (BIS), state government entities, congressional committees, and other US or foreign agencies and regulators.

Our notable recent corporate representations include:

• Volkswagen AG. Steptoe represented Volkswagen AG in the diesel emissions case and successfully negotiated the largest corporate criminal and regulatory settlement in recent history.
• Global Automobile Manufacturer. Steptoe represented one of the world's most prominent automobile manufacturers in an investigation by the DOJ into alleged fraud in connection with vehicle certifications; the investigation was closed without any charges.
• Chinese Information and Communications Technology Company. Steptoe is defending this company in a criminal investigation involving alleged theft of trade secrets, wire fraud, and obstruction of justice.
• Chinese Telecom Company. Steptoe is representing this company in a DOJ investigation into alleged theft of trade secrets.
• Global Motorcycle Company. Steptoe represented a leading luxury motorcycle brand in a DOJ and SEC investigation of alleged fraud in reporting of sales figures and revenue, resulting in a declination by both agencies.
• Control Components, Inc. Steptoe represented UK conglomerate IMI plc, and its US subsidiary Control Components Inc., in a global FCPA investigation. After a self-disclosure and extensive cooperation, Steptoe successfully obtained a declination for IMI and negotiated a plea agreement for CCI that included a substantially below-Guidelines fine amount.
• iFinex and Tether. Steptoe represented 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.
• Global Automobile Manufacturer. Steptoe represented one of the world’s largest automobile manufacturers in a DOJ False Claims Act investigation, resulting in a DOJ decision not to intervene and the dismissal of the complaint.
• Cryptocurrency Mining Company. Steptoe represented one of the world's largest Bitcoin mining companies in an investigation by the DOJ, resulting in no charges.
• Offshore Drilling Contractor. Steptoe represented an offshore drilling contractor in a DOJ and SEC investigation of potential FCPA violations, resulting in the closure of both investigations without enforcement action.
• Japan Airlines. Steptoe represented Japan Airlines in the DOJ air cargo cartel criminal antitrust investigation and successfully negotiated a guilty plea for the company. Steptoe also defended the company in an air cargo cartel investigation before the European Commission and the Swiss Competition Authority.
• Japanese Wastewater Treatment Company. Steptoe represents a company facing allegations of criminal False Claims Act violations in connection with work performed under contracts with the US Navy.
• Private Security Contractor. Steptoe represents this company in connection with an investigation of potential export control violations arising out of the import and re-export of defense articles originating from China.
• Interdealer Brokerage. Steptoe represents this company in connection with an SEC investigation into allegations of violations of Regulation ATS.
• Wood Flooring Company. Steptoe represents this company in a DOJ False Claims Act investigation arising out of allegedly false customs-related documentation regarding country-of-origin information.