Leo Tsao is a partner in the Fintech & Payments and Investigations & White Collar Defense practices at Paul Hastings and is based in the firm’s Washington, D.C. office.
Mr. Tsao’s practice focuses on internal corporate investigations, defense of criminal and regulatory enforcement actions, and compliance counseling. Before Paul Hastings, Mr. Tsao served for more than 15 years as a white collar prosecutor with the Department of Justice (DOJ), where he led or supervised many of the DOJ’s most significant corporate cases involving the Bank Secrecy Act (BSA), the International Emergency Economic Powers Act, the Foreign Corrupt Practices Act (FCPA), and other white collar crimes.
Most recently, Mr. Tsao served as the Principal Deputy Chief of the DOJ’s Money Laundering and Asset Recovery Section (MLARS) and as Chief of MLARS’s Bank Integrity Unit. At MLARS, he was responsible for overseeing the DOJ’s enforcement program against financial institutions for BSA, money laundering, and similar violations, including criminal charges, deferred prosecution agreements, and non-prosecution agreements involving financial institutions. In particular, Mr. Tsao helped lead the DOJ’s enforcement efforts with respect to crimes involving cryptocurrency and FinTech companies, and was involved in drafting the DOJ’s Cryptocurrency Enforcement Framework. Mr. Tsao has worked in close coordination with many domestic regulators, including the Securities and Exchange Commission, the Financial Crimes Enforcement Network, the Office of the Comptroller of the Currency, and the Office of Foreign Assets Control. Mr. Tsao was also responsible for helping to oversee the DOJ’s national Asset Forfeiture Program.
Before MLARS, Mr. Tsao spent three years as an Assistant Deputy Chief in the Fraud Section’s FCPA Unit and eight years as an Assistant U.S. Attorney in the U.S. Attorney’s Office for the Eastern District of Pennsylvania. While at the DOJ, Mr. Tsao helped develop enforcement policies on corporate investigations, compliance, monitorships, charging decisions, and resolutions. Mr. Tsao has also served as lead trial counsel in 10 criminal trials and has argued and/or briefed numerous criminal appeals.
- Assistant Attorney General’s Award, Criminal Division, Distinguished Service Award (2021)
- Cornell Law School, J.D. (magna cum laude), 1998
- Rutgers University, B.A., 1992
- A Commitment to Transparency: Clarifying Key Enhancements to the U.S. Department of Justice’s Corporate Enforcement Guidance - March 30th, 2023
- DOJ Announces Pilot Program and Updated Guidance: Individual Accountability is a Top Priority - March 9th, 2023
- DOJ's Approach to Ephemeral Messaging is Not Ephemeral: New Guidance on Messaging, Personal Devices - March 8th, 2023
- The Impact of United States v. Banks on Securities and Commodities Fraud Sentencing - February 8th, 2023
- Bigger Carrots, More Sticks? DOJ Revises Its Corporate Criminal Enforcement Policy - January 20th, 2023
- Top PHive Crypto Enforcement Notes: January Edition - January 13th, 2023
- Top PHive Crypto Enforcement Notes: December Edition - December 8th, 2022
- Top PHive Crypto Enforcement Notes: November Edition - November 4th, 2022
- Latest DOJ Guidance and Non-US Companies: What to Expect and How to Handle it - November 3rd, 2022
- New Enforcement Policies Signal an Important Shift in DOJ’s Approach to Corporate Prosecutions - September 20th, 2022
- Top PHive Crypto Enforcement Notes: September Edition - September 7th, 2022
- The End of the China Initiative and the Future of U.S. Enforcement against Chinese Companies - May 23rd, 2022
Engagement & Publications
- New York City Bar, International White Collar Crime Symposium 2021, Global Enforcement Trends (Nov. 30, 2021)*
- Wall Street Journal Risk and Compliance Forum, Interview on Cryptocurrency Enforcement (Oct. 12, 2021)*
- Cambridge Forum, Sanctions & AML Compliance, Government Enforcement Panel (Sept. 14, 2021)*
- Guidehouse, Directors Roundtable, Who is Responsible for Corporate Misconduct? (Mar. 16, 2021)*
- Asian American Bar Association of New York, Fall Conference 2020: Enforcement in a Fragmented World (Nov. 10, 2020)*
- New York City Bar, International White Collar Crime Symposium 2021, The Long Arm of the Law: What the Extra-Territorial Tools of the Department of Justice Mean for Asian Companies and Individuals (Sept. 18, 2019)*
- Securities Industry and Financial Markets Association, AML & Financial Crimes Conference (Feb. 5, 2019)*
- Panelist, GIR Live DC, Corporate Enforcement Panel (Oct. 25, 2018)*
- Keynote Speaker, Casino Essentials AML Conference, Casino Enforcement Speech (Aug. 15, 2018)*
- U.S.-China Business Council, Panelist, FCPA Business Roundtable (May 9, 2017)*
- GIR Anti-Corruption Conference, FCPA Enforcement Speech (Sao Paolo, Brazil) (Oct. 20, 2016)*
- Keynote Speaker, China Anti-Corruption Compliance Forum (Beijing, China) (Jun. 26, 2014)*
* Speaking engagements before joining Paul Hastings LLP
- Corporate Criminal Investigations and Prosecutions (Aspen Publishing) (forthcoming 2022)
- DOJ Cryptocurrency Enforcement Framework (October 2020) (Task Force Contributor)
- Money Moves: Following the Money Beyond the Banking System, 67 Journal of Federal Law and Practice 95 (Sept. 2019).
- Lecturer in Law, Corporate Criminal Investigations, Harvard Law School, 2018-present
- Adjunct Professor, Georgetown University Law Center, 2018-present
- Hon. Robert Boochever, U.S. Court of Appeals for the Ninth Circuit (1998-1999)