Lawyers in the Firm’s Criminal Defense and Investigations Group (CDIG) represent sophisticated clients around the world in high-stakes matters relating to white-collar criminal defense, regulatory enforcement and internal investigations. The Firm has represented global institutions in virtually every major U.S. enforcement initiative, including those involving issues relating to:
  • federal and state securities law violations, including insider trading;
  • commodities fraud and market manipulation;
  • violations of economic sanctions regimes;
  • Bank Secrecy Act and anti-money-laundering;
  • mortgages and the financial crisis;
  • the Foreign Corrupt Practices Act;
  • criminal antitrust matters; and
  • criminal tax matters.
Lawyers in CDIG include eight former federal and state prosecutors; former bank regulatory counsel; and leading practitioners in banking, securities and commodities regulation and enforcement. The team boasts extensive trial experience, having collectively handled more than 125 criminal trials in federal and state courts.
 
The Firm has in-depth experience handling multiagency investigations and cross-border enforcement actions. Its global presence assures clients a comprehensive and seamless defense across multiple jurisdictions and practice areas.
 

SELECTED REPRESENTATIONS

Sullivan & Cromwell’s recent experience includes the following representative matters:
 
  • Economic Sanctions and Bank Secrecy Act:
     
    • The Firm represented ABN AMRO Bank, Barclays, ING Group, Lloyds TSB Bank, Standard Chartered Bank, HSBC Group, and BNP Paribas in the resolution of multiagency criminal and regulatory investigations relating to their compliance with economic sanctions and/or anti-money-laundering regulations.
       
    • S&C acted for J.P. Morgan Chase in its resolution with criminal and bank regulatory authorities relating to dealings with Bernard L. Madoff Investment Securities, and TD Bank in its resolution of civil and regulatory investigations involving its relationship with Scott Rothstein.
  • Benchmark Interest Rate Matters:
     
    • S&C represented Barclays in global investigations relating to Libor and Euribor, including securing from the DOJ the only nonprosecution agreement for any institution that has resolved benchmark interest-rate matters.
       
    • S&C represents two other global financial institutions in ongoing investigations relating to Libor.
       
    • S&C represents a global financial institution in ongoing investigations relating to foreign exchange trading.
  • Insider Trading:
     
    • S&C represented The Goldman Sachs Group, its board of directors and many of its executive officers and employees in matters relating to the civil and criminal prosecution of a former director.
       
    • S&C has represented numerous senior executives of issuers, hedge funds, and trading firms in investigations by the DOJ and SEC relating to insider trading.
  • FCPA:
     
    • S&C represented Tenaris, a global manufacturer of oil and gas pipe, in the resolution of an investigation by the DOJ and SEC, including securing the first-ever SEC deferred-prosecution agreement.
       
    • S&C represents a major European energy company in FCPA investigations related to its oil and gas businesses in North Africa.
       
    • S&C represented companies in the mining, oil and gas, and consumer products industries in ongoing DOJ and SEC investigations in countries around the world.
  • Financial Crisis-Related Investigations:
     
    • S&C represented J.P. Morgan Chase in resolving investigations by multiple agencies relating to mortgage backed securities offerings.
       
    • S&C continues to represent a number of the world’s largest financial services companies in other ongoing criminal and regulatory investigations stemming from the financial crisis.
  • Criminal Antitrust:
     
    • S&C represented British Airways, in global criminal antitrust investigations of price-fixing of fuel surcharges with respect to cargo and passenger air services.
       
    • S&C represents multiple executives in the global investigation relating to auto parts.
  • Individual Representations:
     
    • S&C has represented senior executives and other high-ranking employees in connection with criminal and regulatory investigations involving allegations of, among other things, insider trading, securities fraud, antitrust, tax fraud, bribery, and automobile safety recalls.