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- The Audit Committee of a public company in an SEC investigation and internal investigation.
- A large multinational corporation in a cross-border FCPA investigation out of Canada and China.
- Another large multinational corporation and several of its subsidiaries in multiple matters being investigated and prosecuted out of the USAO and the DOJ, including coordination with nearly a dozen international law firms.
- One of the world’s largest telecommunications companies in litigation and a multi-week civil trial involving theft of trade secrets, RICO, conspiracy, among other claims.
- A public company in a cross-border internal investigation into potential books and records and internal controls violations.
- A high technology company and several executives in a criminal investigation conducted by the USAO, the FDA and the DEA following a raid of its corporate offices. The case was resolved with a US$3 million misdemeanor NPA and no criminal charges against the individuals.
- A CEO in a criminal antitrust investigation, including through the DOJ Antitrust Division’s Leniency Program.
- A corporation and its principals in a criminal antitrust prosecution conducted by the DOJ Antitrust Division and FBI.
- A software company in a public corruption investigation being conducted by the USAO and FBI.
- A government contractor in a public corruption investigation being conducted by the USAO, FBI and Inspector General.
- A government contractor in a Department of Defense Inspector General whistleblower investigation.
- A CEO and Founder, as well as an information technology company, in a criminal tax investigation being conducted by the USAO for the Southern District of New York and the IRS.
- A former controller of a publicly traded company in SEC and Special Litigation Committee investigations relating to revenue recognition issues and earnings restatement.
- A public company in an internal investigation into a senior executive’s eight-figure theft and embezzlement scheme, as well as follow-on federal criminal prosecution of a former senior executive.
- A chemical manufacturing company charged with environmental crimes involving the packing, labelling and transportation of hazardous materials. The case resulted in prosecutors dropping all 10 criminal counts and resolution through a modest civil settlement.
- An American multinational banking and financial services corporation and its senior executive in a federal criminal trial involving more than US$100 million in victim bank losses.
- A multi-billion dollar company in an international investigation into allegations of kickbacks, bid rigging and breach of fiduciary duties.
- Corporate victims before the USAOs in criminal theft of trade secrets cases.
- A Fortune 10 company (and several of its subsidiaries) in criminal and administrative FCPA investigations relating to alleged kickbacks paid to the Iraqi government during the U.N.-sponsored Oil-for-Food Program. Defense culminated in the DOJ declining to bring criminal charges and SEC resolving the case on favorable terms.
- A Fortune 200 company against criminal allegations of price manipulation in the natural gas market relating to the California energy crisis. Negotiated US$50 million DPA with the DOJ and the USAO for the Northern District of California.
- A major insurer in a US$90 million arbitration of cross-border loans and political risk insurance. The case was resolved with a favorable settlement for the client.
Featured Matters as a Federal Prosecutor
- Convicted the owner and operator of a defunct Chicago hospital, Edgewater Medical Center, in one of the district’s first-ever Sarbanes-Oxley conspiracy cases, with complex offshore trusts and monetary judgments totaling more than US$188 million.
- Convicted one of the nation’s “Top 10 Most Wanted” mortgage fraud defendants as part of a long-term undercover fraud investigation.
- Member of Silk Road Task Force; convicted the world’s largest online drug trafficker on Silk Road, described then by the government in court filings as the most sophisticated and extensive criminal marketplace of its kind on the Internet.
- Designated as the government’s nationwide point of contact for a Top International Criminal Organization Target (TICOT) and led the government’s money laundering investigation into one of the largest global digital currency exchangers and its top executive.
- Investigated and prosecuted the largest criminal customs fraud, food fraud, and international trade fraud cases in U.S. history, the first in 2010 at nearly US$80 million, and the second series in 2013 at nearly US$180 million, for a total of approximately US$260 million.
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Title:
Mr.
Company
Dechert LLP
Profile Info
Name
Andrew Boutros
About / Bio
Andrew S. Boutros is Regional Chair of Dechert LLP's U.S. White Collar practice and is resident in the firm’s Chicago and Washington, D.C. offices. He is a trial attorney, white collar litigator, Foreign Corrupt Practices Act (FCPA) practitioner, Lecturer in Law at the University of Chicago Law School, voting Member of the ABA Criminal Justice Section Council, Co-Founder and National Co-Chair of the ABA’s Global Anti-Corruption Committee, board member to various professional and legal organizations, and former law clerk on the Sixth Circuit Court of Appeals. A decorated former federal financial fraud prosecutor, Mr. Boutros now represents clients in their important white collar matters; internal investigations; and complex litigations. He also provides strategic counseling and advice to clients in a variety of industries and conducts comprehensive compliance audits. And, he has served as counsel to the independent monitor in an Department of Labor matter.
White Collar and Investigative Experience: Mr. Boutros represents companies large and small, public and private, victims and targets as well as their boards, audit committees, officers, directors and other individuals in government enforcement matters (DOJ, USAO, FBI, SEC and other agencies) and internal investigations. Mr. Boutros has personally represented clients in matters involving general fraud, embezzlement, the Travel Act, FARA, OFAC, RICO, tax, commercial bribery, kickback schemes, public corruption, Inspector General investigations, insurance fraud, bank fraud, securities and accounting violations, healthcare and FDA violations, environmental crimes, trade secret theft, cyber hacking and extortion incidents, criminal antitrust violations, supply chain issues, government contract disputes involving allegations of wrongdoing, whistleblower allegations and the False Claims Act, among others. Mr. Boutros also has significant experience handling criminal customs, trade and antidumping duty fraud cases. Since the early 2000s, he has conducted FCPA investigations in Canada, China, Europe and the Middle East and advised clients on FCPA corporate compliance matters and programs. In addition, Mr. Boutros was retained as an FCPA expert to render a formal legal opinion in a transnational post-acquisition dispute.
United States Attorney’s Office: For most of his nearly eight-year prosecutorial career, Mr. Boutros served in the Financial Crimes and Special Prosecutions Section of the Chicago U.S. Attorney’s Office. His investigations and prosecutions spanned the globe and have been described as among the most extensive and complex multi-district, international corporate fraud and cybercrime cases in the nation’s history. In total, Mr. Boutros coordinated efforts with international law enforcement authorities in more than 20 countries and charged and prosecuted crimes involving some $500 million in losses, proceeds and judgments, while also investigating additional criminal conduct in the several billions of dollars. The media has described Mr. Boutros’s fraud cases as bringing “to mind images of Al Capone and organized crime.”
In this regard, Mr. Boutros led the prosecution of Chicago’s historic “Silk Road” case; convicted the world’s largest online drug trafficker on Silk Road; convicted one of the country’s “Top 10 Most Wanted” mortgage fraud defendants; convicted Edgewater Medical Center’s owner and operator for crimes relating to more than $188 million in judgments; and convicted all apprehended defendants in the most extensive international criminal trade fraud, food fraud and corporate social responsibility series of cases of their kind, which Bloomberg Businessweek described as “the largest food fraud in U.S. history.” While in the Office, the United States Attorney’s Office publicly recognized Mr. Boutros’s work, announcing that “[s]ome of the largest criminal fines and restitution for FY 2014 came from . . . a series of cases” Mr. Boutros successfully prosecuted.
In addition, while in the U.S. Attorney’s Office, Mr. Boutros handled hundreds of matters; briefed and argued appeals to the Seventh Circuit Court of Appeals, including the government’s important “Iraqi sleeper spy” case; and tried or prepped for trial dozens of cases. His trials involved charges of wire fraud, mail fraud, bank fraud, bankruptcy fraud, and false statements affecting financial institutions, among others. Mr. Boutros is also among a select few prosecutors to ever insert an undercover federal agent into a real, non-government corporation; he did so as part of a sweeping, long-term fraud investigation into an entire industry’s supply chain.
Experience Negotiating Corporate Pre-Trial Diversion Agreements: A recognized authority on corporate deferred and non-prosecution agreements, Mr. Boutros has drafted and negotiated corporate DPAs both as a defense attorney and prosecutor. In private practice, Mr. Boutros negotiated a $50 million deferred prosecution agreement for a publicly-traded company facing criminal charges for price manipulation in the natural gas market relating to the California energy crisis. He also obtained a non-prosecution agreement for a different company in a criminal investigation conducted by the USAO, the FDA and the DEA following a raid of its corporate offices; the case was resolved with a $3 million misdemeanor NPA and no criminal charges against the individuals. Mr. Boutros also represented a chemical manufacturing company charged with environmental crimes involving the packing, labeling and transportation of hazardous materials; the case resulted in prosecutors dropping all 10 criminal counts and resolution through a modest civil settlement. As a prosecutor, Mr. Boutros proposed, negotiated, and entered into among two of the Northern District of Illinois’s first corporate DPAs. He is also the author of the Department of Justice’s first customs-based supply chain corporate compliance program based on “reasonable country of origin inquiry,” the same standard found in Dodd-Frank’s conflict-mineral rules.
White Collar and Investigative Experience: Mr. Boutros represents companies large and small, public and private, victims and targets as well as their boards, audit committees, officers, directors and other individuals in government enforcement matters (DOJ, USAO, FBI, SEC and other agencies) and internal investigations. Mr. Boutros has personally represented clients in matters involving general fraud, embezzlement, the Travel Act, FARA, OFAC, RICO, tax, commercial bribery, kickback schemes, public corruption, Inspector General investigations, insurance fraud, bank fraud, securities and accounting violations, healthcare and FDA violations, environmental crimes, trade secret theft, cyber hacking and extortion incidents, criminal antitrust violations, supply chain issues, government contract disputes involving allegations of wrongdoing, whistleblower allegations and the False Claims Act, among others. Mr. Boutros also has significant experience handling criminal customs, trade and antidumping duty fraud cases. Since the early 2000s, he has conducted FCPA investigations in Canada, China, Europe and the Middle East and advised clients on FCPA corporate compliance matters and programs. In addition, Mr. Boutros was retained as an FCPA expert to render a formal legal opinion in a transnational post-acquisition dispute.
United States Attorney’s Office: For most of his nearly eight-year prosecutorial career, Mr. Boutros served in the Financial Crimes and Special Prosecutions Section of the Chicago U.S. Attorney’s Office. His investigations and prosecutions spanned the globe and have been described as among the most extensive and complex multi-district, international corporate fraud and cybercrime cases in the nation’s history. In total, Mr. Boutros coordinated efforts with international law enforcement authorities in more than 20 countries and charged and prosecuted crimes involving some $500 million in losses, proceeds and judgments, while also investigating additional criminal conduct in the several billions of dollars. The media has described Mr. Boutros’s fraud cases as bringing “to mind images of Al Capone and organized crime.”
In this regard, Mr. Boutros led the prosecution of Chicago’s historic “Silk Road” case; convicted the world’s largest online drug trafficker on Silk Road; convicted one of the country’s “Top 10 Most Wanted” mortgage fraud defendants; convicted Edgewater Medical Center’s owner and operator for crimes relating to more than $188 million in judgments; and convicted all apprehended defendants in the most extensive international criminal trade fraud, food fraud and corporate social responsibility series of cases of their kind, which Bloomberg Businessweek described as “the largest food fraud in U.S. history.” While in the Office, the United States Attorney’s Office publicly recognized Mr. Boutros’s work, announcing that “[s]ome of the largest criminal fines and restitution for FY 2014 came from . . . a series of cases” Mr. Boutros successfully prosecuted.
In addition, while in the U.S. Attorney’s Office, Mr. Boutros handled hundreds of matters; briefed and argued appeals to the Seventh Circuit Court of Appeals, including the government’s important “Iraqi sleeper spy” case; and tried or prepped for trial dozens of cases. His trials involved charges of wire fraud, mail fraud, bank fraud, bankruptcy fraud, and false statements affecting financial institutions, among others. Mr. Boutros is also among a select few prosecutors to ever insert an undercover federal agent into a real, non-government corporation; he did so as part of a sweeping, long-term fraud investigation into an entire industry’s supply chain.
Experience Negotiating Corporate Pre-Trial Diversion Agreements: A recognized authority on corporate deferred and non-prosecution agreements, Mr. Boutros has drafted and negotiated corporate DPAs both as a defense attorney and prosecutor. In private practice, Mr. Boutros negotiated a $50 million deferred prosecution agreement for a publicly-traded company facing criminal charges for price manipulation in the natural gas market relating to the California energy crisis. He also obtained a non-prosecution agreement for a different company in a criminal investigation conducted by the USAO, the FDA and the DEA following a raid of its corporate offices; the case was resolved with a $3 million misdemeanor NPA and no criminal charges against the individuals. Mr. Boutros also represented a chemical manufacturing company charged with environmental crimes involving the packing, labeling and transportation of hazardous materials; the case resulted in prosecutors dropping all 10 criminal counts and resolution through a modest civil settlement. As a prosecutor, Mr. Boutros proposed, negotiated, and entered into among two of the Northern District of Illinois’s first corporate DPAs. He is also the author of the Department of Justice’s first customs-based supply chain corporate compliance program based on “reasonable country of origin inquiry,” the same standard found in Dodd-Frank’s conflict-mineral rules.
Experience
Corporate Monitoring Exp
- Mr. Boutros has served as counsel to the independent monitor in an Department of Labor matter governed by an administrative agreement.
Professional Experience
Featured Matters as a White-Collar Practitioner
Education
Education
JD, University of Virginia School of Law
B.S., Virginia Tech, in-honors summa cum laude
Phi Beta Kappa
Affiliations
Professional Memberships
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- International Association of Independent Corporate Monitors, Board Member (2015 – present)
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- American Law Institute, Member (2015 – present)
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- American Bar Foundation, Life Fellow (2014 – present)
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- ABA Criminal Justice Section Council, Voting Member (2013 – 2019); Advisor to the Council (2012 – 2013)
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- ABA Criminal Justice Section Global Anti-Corruption Committee, Co-Founder & National Co-Chair (2010 – present)
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- ABA International Law Section, Corporate Social Responsibility Committee, Senior Advisor (2013 – present)
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- ABA Task Force on College Due Process Rights and Victim Protection, National Chair (2016)
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- ABA Criminal Justice Section CLE Board Membership, Board Member (2014 – present)
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- ABA Section Officers Conference (SOC) Annual Meeting Task Force, Representative (2012 – 2013)
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- Bloomberg BNA Criminal Law Reporter and White Collar Crime Report, Advisory Board Member (2010 – present)
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- Chicago Crime Commission, Member (2016 – present)
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- Federal Law Enforcement Officers Association – Chicago Chapter, Chief Business Officer & Board Member (2014 – 2016); Associate Member (2012 – present)
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- Mitchell A. Mars Foundation, Board Member (2014 – present)
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- ABA National Institute on Int’l Regulation & Compliance: FCPA, Economic Sanctions & Export Control, Institute Chair (2013 – 2014)
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- ABA Conference Planning Committees
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- Ninth Annual Criminal Justice Section Fall Institute, Planning Committee Member (2016)
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- Global White Collar Crime Institute (Shanghai), Planning Committee Member (2014 – 2015)
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- Sixth Annual National Institute on the FCPA, Planning Committee Member (2013)
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- Fifth Annual National Institute on the FCPA, Planning Committee Member (2012)
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- ABA Conference Planning Committees
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- University of Chicago Law School Corporate Lab, Advisor to the Lab (2011 – present)
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- University of Chicago Law School Legal Forum on Combating Corruption Symposium, Faculty Leader (2011)
Contact Info
Email
andrew.boutros@dechert.com
