Chris is chair of the firm’s white collar and regulatory defense group and a partner in the litigation group. He is an accomplished trial lawyer with over 25 years of experience litigating both criminal and civil matters. He co-leads the firm’s government enforcement and investigations practice, and leads its white-collar criminal defense practice. Chris frequently represents corporations, audit committees, and executives in internal investigations and before the DOJ, SEC, and other government enforcement agencies in a variety of matters, including: financial and accounting issues, the Foreign Corrupt Practices Act, insider trading, U.S. export control and economic sanctions violations, unfair competition, trade secret theft, antitrust violations, mail and wire fraud, money laundering, and tax fraud, among others. In addition, he frequently advises corporations and boards on the design and implementation of corporate compliance programs, as well as corporate governance and disclosure issues.

Before joining the firm in 2007, Chris served as a federal prosecutor in San Francisco for six years where he was a member of the Securities Fraud Section and prosecuted a variety of white-collar crimes. Chris worked closely with the SEC in San Francisco, Los Angeles, New York, Washington, D.C., and elsewhere while conducting corporate fraud investigations. During his tenure as an Assistant U.S. Attorney, Chris represented the United States in over a dozen high-profile jury trials and evidentiary hearings and numerous appeals before the Ninth Circuit. He was lead counsel in several stock option backdating investigations involving Silicon Valley companies, investigations of technology companies for revenue recognition fraud, and other corporate fraud investigations.

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  • Representative Experience
    • Represented Hewlett-Packard Company before DOJ and the SEC in a four-year FCPA investigation involving multiple countries; negotiated successful resolution with no criminal disposition for the parent issuer, no compliance monitor, and substantially reduced penalty; successfully guided successor companies through three-year, post-resolution compliance period, including enhancements to anti-corruption compliance program and preparation and submission of annual compliance reports to DOJ and the SEC
    • Represented HeadSpin, Inc. in a SEC investigation and resolution of accounting fraud allegations where the SEC imposed no monetary penalty because of the quality of the company’s internal investigation, cooperation, remediation; the Director of the SEC’s Division of Enforcement stated in the SEC’s press release: “For companies wondering what types of remedial actions and cooperation might be credited by the Commission after a company uncovers fraud, this case offers an excellent example.”
    • Represented Inuit Inc. in publicly reported whistleblower case and related DOJ, SEC, FTC, and state attorneys general investigations involving allegations that company knowingly allowed fraudulent tax returns to be filed through its TurboTax service; matter closed without enforcement action
    • Conducted over 100 investigations into FCPA-related issues for multinational companies in countries throughout the world, including in Asia, Europe, Africa, South America, and Central America; represented companies in related DOJ and SEC investigations
    • Represented Fortune 100 technology company in suspension and debarment proceedings initiated by the World Bank Integrity Vice Presidency; successfully moved for withdrawal of the notice of sanctions proceeding before the World Bank Chief Suspension and Debarment Officer; matter closed without further action
    • Represented over 150 employees of Wells Fargo in connection with DOJ, SEC, OCC, and state attorneys general investigations into the bank’s publicly disclosed sales practices scandal involving the creation of fraudulent checking and savings accounts; successfully resolved without enforcement action initiated against any clients
    • Led internal investigations for several companies and boards into allegations relating to accounting and financial improprieties, kickbacks, embezzlement, corruption, and SOX-related issues
    • Represented CEOs, CFOs, and other executives in DOJ and SEC investigations relating to accounting fraud, as well as related shareholder and derivative litigation
    • Represented former CFO of Silicon Valley semiconductor company in connection with SEC resolution of insider trading allegations
  • Judicial Clerkships
    • Honorable James R. Browning, United States Court of Appeals for the Ninth Circuit
    • Honorable Harry L. Hupp, United States District Court for the Central District of California
  • Professional Activities
    • Board Member, Association of Business Trial Lawyers; former Editor and Chief of the ABTL Report
    • Former Chair, Securities Litigation Section, Bar Association of San Francisco
    • Executive Committee, Northern District of California Chapter, Federal Bar Association
  • Speaking Engagements and Media
    • SEC Spares Tech Firm Fines In Effort To Play Up Remediation, Law360, January 28, 2022
    • How to Successfully Leverage New Technologies for Internal Investigations, 11th West Coast Conference on FCPA Compliance & Enforcement, American Conference Institute, San Francisco, CA, September 25 – 26, 2018 (presenter)
    • Third Party Due Diligence & Monitoring for New and Existing Partners, 10th West Coast Conference on FCPA Compliance & Enforcement, American Conference Institute, San Francisco, CA, September 26 – 27, 2017 (presenter)
    • Insider Trading Law Remains Murky After High Court Ruling, Law360, December 6, 2016
    • Justices Unlikely To Slice Through Insider Trading Knot, Law360, October 7, 2016
    • The “Risk-Based” Anti-Corruption Compliance Program – What It Is, Why You Need One, and How You Can Create One, 7th West Coast Conference on FCPA Compliance & Enforcement, American Conference Institute, San Francisco, CA, September 23 – 24, 2014 (presenter)
    • The Fundamentals of Foreign Corrupt Practices Act Compliance, 6th West Coast Conference on FCPA Compliance & Enforcement, American Conference Institute, San Francisco, CA, October 1 – 2, 2013 (presenter)
    • Securities Litigation Department of the Year, The Recorder, October 14, 2013
    • Monitoring Third Parties’ Anti-Corruption Compliance: How to Conduct Pre-Contract Due Diligence in High Risk Markets and Implement Robust Management Protocols for Existing Distributors, Brokers, Agents and Intermediaries, 5th West Coast Conference on FCPA Compliance & Enforcement, American Conference Institute, San Francisco, CA, October 2 – 3, 2012 (presenter)
    • Developing the Next Generation of Leaders in the Securities Litigation Bar, The Bar Association of San Francisco, March 2010
    • Madoff behind bars, but probe grinds forward, Associated Press, July 1, 2009
    • Peter John Schuller, Is Madoff the Tip of the Iceberg?, KQED Radio, June 30, 2009
    • Must A Corporation Disclose Privileged Information To Avoid Prosecution, And If It Does So, Will It Be At The Mercy Of The Plaintiffs’ Bar? – Recent Developments In DOJ Policy And Case Law, Fenwick & West Securities Litigation Update, January 21, 2009
    • Tough Post-Enron Regulations No Match for Satyam CEO, Investor's Business Daily, January 8, 2009
    • Ethical Issues for In-House Counsel: Staying out of Trouble and Getting out of Trouble, ACC Corporate & Securities Law Committee, December 9, 2008 (presenter)
    • DOJ Targets Approximately 20,000 Investors as Co-Conspirators in Criminal Tax Fraud Investigation of UBS, Fenwick & West Litigation Alert, November 19, 2008
    • Thomas Bron, Greasy Palms: When bribery investigations become public, expect follow-on civil suits, California Lawyer, September 2008
    • Mid-year Report on Insider-Trading Enforcement, Compliance Week, July 25, 2008
    • The Foreign Corrupt Practices Act: The Next Corporate Scandal?, Fenwick & West Securities Litigation Alert, January 28, 2008
    • Insider Trading Is Back, Fenwick & West Securities Litigation Alert, September 4, 2007

Representative Clients

  • Alibaba
  • American Express
  • AVEVA Group
  • DXC Technology
  • Hewlett Packard Enterprise
  • HP Inc.
  • Intuit
  • Juniper Networks
  • Wells Fargo

Education & Admissions

J.D., magna cum laude, Harvard Law School

B.A., summa cum laude, English
Dartmouth College

Admitted to practice in California and New York


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