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Overview

Nathaniel Edmonds serves as the Co-Chair of the firm’s litigation practice in Washington, D.C., which houses over 100 lawyers handling a variety of litigation matters, including internal corporate investigations, white collar criminal defense, anti-corruption compliance, sanctions and export controls, data privacy and cyber security, intellectual property and patent litigation, international arbitration, and antitrust counseling.  Mr. Edmonds focuses on global internal investigations, in particular, anti-corruption matters and the challenges arising from multi-jurisdictional investigations into complex economic crime.  He also conducts internal investigations and advises companies on significant sanctions and export control matters before regulatory agencies, including the Department of Treasury’s Office of Foreign Assets Control (OFAC) and the Department of Commerce’s Bureau of Industry and Security (BIS).

As a former Assistant Chief of the Foreign Corrupt Practices Act (FCPA) Unit of the Fraud Section in the Criminal Division of the Department of Justice (DOJ), Mr. Edmonds assisted in the supervision of all FCPA cases in the United States and was one of the principal drafters of the first edition of A Resource Guide to the U.S. Foreign Corrupt Practices Act, published in November 2012 by the DOJ and the Securities and Exchange Commission (SEC), which has been updated in July 2020 and is available at http://www.justice.gov/criminal-fraud/fcpa-resource-guide. Mr. Edmonds also specializes in anti-corruption compliance risk assessments and due diligence, as well as developing and overseeing compliance programs. During his nearly 10 years as a federal white collar prosecutor, Mr. Edmonds handled numerous complex economic criminal investigations and jury trials, including the FCPA and export control-related conviction of a major aerospace and defense contractor, the fraud and domestic corruption matters associated with lobbyist Jack Abramoff, and various accounting and securities fraud matters. During his tenure at the Department of Justice, Mr. Edmonds worked with prosecutors, law enforcement and regulators from six continents on corruption matters, including as a U.S. Delegate to the OECD’s Working Group on Bribery, with the UK’s Serious Fraud Office and as a member of the U.S.-China Joint Liaison Group’s Anti-Corruption Working Group.

Recognitions

  • Ranked by Chambers USA Nationwide for FCPA (2018-2024)
  • The Legal 500 USA, Corporate Investigations and White-Collar Criminal Defense: Advice To Individuals (2022)
  • Recipient of the 2014 Burton Award for Distinguished Legal Writing
  • Named by Ethisphere as one of the 2014 FCPA Attorneys that Matter ("Specialists - Private Practice") 
  • Named by Ethisphere as one of the 2012 FCPA Attorneys that Matter (“Government Stars”)
  • Recognized by the U.S. Department of Justice for his investigation and trial successes, including:
    • The 2011 Attorney General’s Award for Distinguished Service related to the investigation and trial convictions in a fraud and domestic corruption matter.
    • The 2010 Attorney General’s Award for Fraud Prevention for his leadership in the investigation and conviction of a major international defense contractor for FCPA-related offenses.

Education

  • University of Chicago, J.D. (cum laude); Order of the Coif 
  • Princeton University, A.B.

Representations

  • Represented a European aerospace company before the U.S. Department of Justice with respect to allegations of bribery and export control violations that resulted in the largest coordinated anti-corruption resolution with UK and French criminal enforcement authorities, and continuing to represent them with respect to post-DPA investigation and compliance obligations.
  • Represented a U.S. company under the FCPA pilot program, resulting in a DOJ declination with disgorgement and conditional non-Debarment from the World Bank.
  • Represented a Fortune 20 company before the DOJ and SEC in connection with an FCPA investigation, resulting in declinations from both government agencies.
  • Represented a Chinese joint venture before the DOJ and SEC in connection with an FCPA investigation, resulting in declinations from both government agencies.
  • Represented a South American company regarding enhancements to its anti-corruption compliance programs, interactions with an independent compliance monitor and compliance self-reporting as required as part of DOJ and SEC FCPA resolutions.
  • Prepared an expert witness report regarding the financial impact of an FCPA investigation and compliance failures.
  • Conducting anti-corruption risk assessments for U.S. and non-U.S. companies to identify gaps in anti-corruption compliance programs and appropriate enhancements to minimize future risk.
  • Providing FCPA legal advice and anti-corruption compliance counseling to leading Fortune 100 and Global 500 multinational corporations, including financial services, consumer products, technology, real estate, life science, aerospace, and defense companies.
  • Conducting third party and transactional due diligence on multiple continents for numerous private equity funds, financial institutions, and companies.

news

    Recognitions

    insights

    Engagement & Publications

    • December 2023, Co-Author, “More Clarity on the Horizon for FCPA Resolutions? DOJ and SEC Officials Discuss Enforcement Trends“
    • December 2023, Co-Author, “Safe Harbor in the Coming Enforcement Storm? DOJ Announces New M&A Policy to Encourage Compliance“
    • October 2023, Co-Author, “First-of-its-Kind E5 Joint Guidance Prioritizes Industry Compliance to Prevent Diversion of Items Critical to Russian Weapons Systems“
    • August 2023, Co-Author, “DOJ OFAC BIS Joint Compliance Note and Enhanced Coordination Highlights Increased Enforcement Risk,”
    • January 2023, Co-Author, “Bigger Carrots, More Sticks? DOJ Revises Its Corporate Criminal Enforcement Policy
    • September 2022, Co-Author, “New Enforcement Policies Signal an Important Shift in DOJ’s Approach to Corporate Prosecutions
    • November 2021, Co-Author, “A Revitalization of Global Anti-Corruption Enforcement: The OECD Issues New Recommendations Likely to Increase Multijurisdictional Enforcement and Spur Additional Investments in Compliance
    • June 2021, Co-Author, “China Enacts Anti-Foreign Sanctions Law: Increasing Uncertainty for Companies with China Operations
    • May 2021, "The Second Edition of the FCPA Guide and FCPA Enforcement Report for 2020-2021," 5th Anti-Bribery and Anti-Corruption Compliance China Summit
    • April 2021, "Ethical Issues in FCPA Practice: Critical Compliance Topics," Practising Law Institute, The Foreign Corrupt Practices Act and International Anti-Corruption Developments 2021
    • December 2020, "A Discussion on Transnational Corruption with Drago Kos, Chair of the OECD's Working Group on Bribery"
    • December 2020, "The Second Edition of the FCPA Guide and FCPA Enforcement Report for 2020," 3rd Anti-Bribery and Anti-Corruption Compliance China Summit
    • Co-author, November 2020, "OECD's Working Group on Bribery Applauds United States for Continued Enforcement of FCPA and Recommends Additional Steps to Increase Guidance"
    • Co-author, July 2020, "Evolution not Revolution:  DOJ and SEC Update The FCPA Resource Guide"
    • Co-author, July 2020, "Sacre Blue! France Sends a Message in the Fight Against Foreign Bribery"
    • Co-author, September 2019, "CFTC Paying for a Company's Dirty Laundry: New Whistleblower Initiatives and Rewards Suggest Increased Enforcement in the Virtual Currency, Foreign Corrupt Practices, Insider Trading, and BSA Spaces"
    • Co-author, June 2019, "CFTC Reaffirms Focus on Foreign Corrupt Practices"
    • April 2019 (New York, NY) “Taking Your Compliance Program to the Next Level,” Practising Law Institute, FCPA and International Anti-Corruption Developments 2019
    • November 2018 (Basel, Switzerland) “Official Launch of the Tainted Assets Initiative,” Anti-Corruption Collective Action: Evolution to Revolution
    • September 2018 (San Francisco, CA) “Enhanced Coordination Versus 'Piling On' — How Recent DOJ Policy Announcements are Affecting Multinationals’ Penalty Risk Assessments and Prospects of Double Jeopardy,” American Conference Institute, 11th West Coast Conference on FCPA Enforcement and Compliance
    • October 2017 (Las Vegas, NV) “From FCPA Prosecutors to Company Protectors: Top 10 Lessons Learned from the Front Lines of FCPA Enforcement” The Society of Corporate Compliance & Ethics 16th Annual Compliance and Ethics Institute
    • September 2017 (Paris, France) “The Tainted Assets Initiative: Encouraging Dialogue to Agree on Guidelines” ETHIC Intelligence 2nd Annual International Conference, Standards and Guidelines in Anti-Corruption Compliance
    • July 2017 (Boca Raton, FL) Guest Speaker, Ernst & Young Americas FIDS Executive Conference
    • June 2017 (New York, NY) “Prosecutor Alumni Panel: What’s Next? How has the Risk Map Changed? – How Life Sciences Companies Should Determine Where and How Much to Invest in Anti-Corruption Compliance” American Conference Institute’s 11th Advanced Forum on FCPA and Anti-Corruption in the Life Sciences Industry
    • May 2017 (Irving, TX) “DOJ Compliance Program Evaluation Guidance” North Texas Ethics & Compliance Council
    • May 2017 (Dallas, TX) “Leveraging Compliance to Optimize Performance” Deloitte Roundtable, Managing Global Compliance Risks in a Franchise Environment
    • October 2016 (New York, NY) “How to Build A Compliance System and to Prevent Corruption in A Medium European Group with Global Challenges” Duxes 2nd Global Anti-corruption Compliance Summit 2016
    • September 2016 (Chicago, IL) “From FCPA Prosecutors to Company Protectors: Lessons from Former DOJ FCPA Unit Prosecutors on How to Best Protect Your Company from the Risks of Corruption” The Society of Corporate Compliance and Ethics 15th Annual Compliance & Ethics Institute
    • March 2016 (New York, NY) “Recent Trends in FCPA Litigation, Enforcement and Compliance” New York City Bar Association
    • November 2015 (New York, NY) Duxes Global Anti-Corruption Summit 2015
    • October 2015 (Las Vegas, NV) “How to Best Protect Your Company from the Risks of Corruption” The Society of Corporate Compliance & Ethics 14th Annual Compliance & Ethics Institute
    • October 2015 (Washington, D.C.) The Sixteenth Pharmaceutical Compliance Congress and Best Practices Forum
    • September 2015 (Washington, D.C.) “Mitigating Corruption Risk in China” Paul Hastings, Ernst & Young, and The FCPA Report
    • April 2015 (McLean, VA) “FCPA Internal Investigations – Best Practices” The ACES Compliance Summit, Momentum
    • February 2015 (Washington, D.C.) “Private Justice in Public Enforcement” The American Criminal Law Review / Georgetown Law
    • October 2014 (Washington, D.C.) “Developments in the Application and Enforcement of FCPA and Anticorruption Laws of the EU” Council for Senior International Attorneys
    • October 2014 (Miami, FL) ACI’s Anti-Corruption Boot Camp
    • September 2014 (Chicago, IL) Society of Corporate Compliance and Ethics Annual Compliance & Ethics Institute
    • September 2014 (Braselton, GA) ABA Criminal Justice Section’s Southeastern White Collar Crime Institute
    • August 2014 (Seattle, WA) Law Seminars International’s Anti-Corruption Compliance in China
    • June 2014 (New York, NY) Corporate Counsel’s Annual General Counsel Conference
    • April 2014 (New York, NY) American Conference Institute’s FCPA and Anti-Corruption for the Life Sciences Industry
    • April 2014 (Washington, D.C.) Dow Jones Global Compliance Symposium
    • March 2014 (Washington, D.C.) Momentum’s Global Anti-Corruption Conference
    • January 2014 (New York, NY) Fordham Law/CBLA’s China and the Foreign Corrupt Practices Act: Challenges for the 21st Century
    • December 2013 (Singapore) American Conference Institute’s Summit on Anti-Corruption Compliance and Risk Management
    • December 2013 (Hong Kong) Duxes Anti-Corruption Compliance Asia Pacific Summit
    • October 2013 (Washington, D.C.) Pharmaceutical Compliance Forum’s 14th Annual Pharmaceutical Regulatory and Compliance Congress
    • October 2013 (Alexandria, VA) International Forum on Business Ethical Conduct (IFBEC)’s Annual Meeting, Operating in a Global Environment: Business Aspects
    • October 2013 (Washington, D.C.) International Law Institute’s Governance and Anticorruption Methods
    • October 2013 (Washington, D.C.) Sandpiper Partners’ Fraud, Anti-Corruption, FCPA & Whistleblowers: Latest Developments - Enforcement with Teeth
    • October 2013 (Atlanta, GA) State Bar of Georgia’s 20th Annual Securities Litigation and Regulatory Seminar
    • September 2013 (Washington, D.C.) American Bar Association’s FCPA National Institute
    • September 2013 (Washington, D.C.) U.S. Securities and Exchange Commission’s FCPA Boot Camp - Trends in International Corruption
    • September 2013 (Houston, TX) Momentum’s Oil and Gas Anti-Corruption and Compliance Congress
    • June 2013 (Chicago, IL) American Conference Institute’s FCPA Boot Camp
    • June 2013 (Atlanta, GA) Institute of Continuing Legal Education in Georgia, International Business Crimes: Foreign Corrupt Practices Act, Criminal Antitrust and Export Controls
    • June 2013 (Las Vegas, NV) SEC Hot Topics Institute
    • May 2013 (New York, NY) American Conference Institute’s FCPA and Anti-Corruption for the Life Sciences Industry
    • May 2013 (Seoul, Korea) Asian Century Forum
    • April 2013 (Washington, D.C.) Moderator, Internal Investigations panel, ABA National Institute on Internal Corporate Investigations
    • April 2013 (Washington, D.C.) PwC’s Annual Securities Litigation & Enforcement 2013 Update
    • March 2013 (Washington, D.C.) “Representing Clients in Cross-Border Investigations,” (Edward Bennett Williams Inn of Court)
    • February 2013 (Washington, D.C.) Foreign Bribery Training Conference for Prosecutors and Investigators, “Multi-Jurisdictional Enforcement” and conference moderator for U.S. government sponsored three-day seminar for 130 prosecutors, regulators and law enforcement from 30 countries
    • November 2012 (Washington, D.C.) National Conference on the FCPAFriend or Foe?: A Dissection of a Monitorship from Start to Finish” (ACI)
    • June 2012 (Washington, D.C.) The D.C. Bar Association, “The Foreign Corrupt Practices Act: A Statute Drawing Keen Interest
    • May 2012 (Kazan, Russian Federation) Asia Pacific Economic Cooperation Anti Corruption and Transparency Working Group, “Anticorruption Enforcement and Multijurisdictional Cooperation
    • January 2012 (Houston, TX) FCPA Boot Camp, “Enforcement Highlights and What the Latest Cases Reveal About Compliance Risk Exposure” (ACI)
    • November 2011 (Washington, D.C.) National Conference on the FCPA, “FCPA CASE REVIEW: A Hands-on Look at the 2011 FCPA Cases and What to Take Away” (ACI)
    • November 2011 (Washington, D.C.) Twelfth Annual Pharmaceutical Regulatory and Compliance Congress and Best Practices Forum, “FCPA and UK Bribery Act Enforcement and Compliance Update” (The Pharmaceutical Compliance Forum)
    • June 2011 (Washington, D.C.), ViewPoints For the Audit Committee Leadership Summit,Bribery and Corruption Risks” (Tapestry Networks)
    • May 2011 (Washington, D.C.), “Enforcement of The Foreign Corrupt Practices Act: A Dialogue with Regulators” (Conference Board Webinar)
    • February 2011 (Washington, D.C.) American Bar Association International Law Spring 2011 MeetingChina’s Litigation, Judiciary & Enforcement: Fact or Fiction Panel
    • December 2010 (Abu Dhabi, United Arab Emirates) Abu Dhabi Summit on Anticorruption: Implementing Effective Corporate Governance, Anti-Bribery and FCPA Compliance Programs in the Middle East, “FCPA Enforcement Priorities and How Cases are Coordinated Abroad” (ACI)
    • November 2010 (Washington, DC) National Conference on the FCPA, “How to Represent Individuals in FCPA Investigations” (ACI)
    • September 2010 (Singapore) Anticorruption South and Southeast Asia Summit, “Keynote Address: Explaining the Priorities of the DOJ and SEC” (Beacon)
    • June 2010 (Shanghai, China), 3rd China Summit on Anti-Corruption, “FCPA Enforcement Priorities at U.S. DOJ” (ACI)
    • May 2010 (Beijing, China) “Briefing on the FCPA” (U.S.-China Business Council and the American Chamber of Commerce in China)

    Involvement

    • Previous Assistant Chief of the Foreign Corrupt Practices Act (FCPA) Unit at the United States Department of Justice, Criminal Division, Fraud Section
      • Joined the Fraud Section in 2003 through the Attorney General's Honors Program and was promoted to Assistant Chief of the FCPA Unit in February 2010.
      • Member of the U.S. delegations to numerous international anti-corruption organizations, including the Organization for Economic Cooperation and Development’s Working Group on Bribery.
    • Served as the legal expert on U.S. compliance with international anticorruption treaties and analyzed foreign countries anticorruption legislation.
    • Involved in the approval of FCPA opinion releases and spoke at conferences designed to raise awareness, encourage corporate compliance, and reduce foreign bribery.
    • Adjunct Professor of Law at Georgetown University Law Center (Federal Fraud Prosecution: Theory and Practice  and Criminal Practice Seminar: White-Collar Crimes in a Transnational Context)
    • Clerked for Judge Milton E. Shadur in the U.S. District Court for the Northern District of Illinois
    • Member of the Board of Directors, Mathcounts Foundation

    Practice Areas

    Litigation

    Securities Litigation

    National Security Regulation and Investigations

    Anti-Corruption and FCPA

    Investigations and White Collar Defense

    Congressional Investigations

    International Arbitration

    Compliance & Regulatory Counseling


    Languages

    English


    Admissions

    District of Columbia Bar

    Illinois Bar


    Education

    The University of Chicago Law School, J.D. 2002

    Princeton University, A.B. 1995