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Seyfarth Shaw LLP
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Andrew Boutros
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Andrew S. Boutros is the National Co-Chair of Seyfarth Shaw LLP’s White Collar, Internal Investigations, and False Claims Team. He is a distinguished trial attorney, accomplished litigator, Foreign Corrupt Practices Act (FCPA) pioneer, 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 most sensitive and important white collar matters; internal investigations, including those arising under the FCPA and other anti-corruption laws; and complex litigations. He also provides strategic counseling and advice to clients in a variety of industries and conducts comprehensive compliance audits, including in the areas of corporate social responsibility, country of origin matters, and supply chain integrity. Mr. Boutros is resident in the firm’s Chicago and Washington, D.C. offices.

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 are 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.” In 2014, 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.

FCPA, White Collar and Investigative Experience: A well-respected FCPA practitioner and recognized thought leader in the area, Mr. Boutros has handled FCPA matters for clients since the early 2000s. Most recently, Mr. Boutros was retained as an FCPA expert in a post-acquisition dispute between a U.S. issuer and a European acquiree with significant business in Asia.

Prior to his government service, Mr. Boutros was instrumental in building the FCPA practice of another leading international law firm. During that phase of his private practice career, Mr. Boutros led upwards of 25 attorneys in defending corporations and executives in high-stakes criminal, regulatory and FCPA investigations conducted by the Fraud Section of the Department of Justice, the U.S. Attorneys’ Offices, the Securities and the Exchange Commission, and other government agencies. In this regard, Mr. Boutros spent years defending a Fortune 10 company and several of its subsidiaries in multiple parallel DOJ and SEC high-profile FCPA investigations. His day-to-day handling of those matters led to a complete declination of criminal prosecution by DOJ and a favorable negotiated settlement with the SEC.

In addition, Mr. Boutros has conducted and managed a variety of internal FCPA and other corporate investigations; advised clients on corporate compliance matters, including the FCPA; designed FCPA and other corporate compliance programs; and litigated cases in federal court and in arbitration. As a federal prosecutor, Mr. Boutros provided strategic counseling and advice on the FCPA and other closely related matters. He also has the distinction of being the only prosecutor to convict a previously-convicted FCPA defendant.

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. 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.
Professional Experience

Featured Matters as a White-Collar Practitioner

  • Retained as FCPA expert to render formal legal opinion in trans-national post-acquisition dispute.
  • Representing large multinational corporation in FCPA investigation out of China.
  • Representing high technology company and several executives in criminal investigation conducted by the United States Attorney’s Office, the Food and Drug Administration, and the Drug Enforcement Administration
  • Representing Chief Executive Officer in criminal antitrust investigation, including through DOJ Antitrust Division’s Leniency Program.
  • Representing CEO and Founder as well as information technology company in criminal tax investigation being conducted by the United States Attorney’s Office for the Southern District of New York and the IRS.
  • Representing former controller of publicly traded company in SEC and Special Litigation Committee investigations relating to revenue recognition issues and earnings restatement.
  • Representing public company in internal investigation into senior executive’s theft and embezzlement scheme as well as in follow-on federal criminal prosecution of former senior executive.
  • Represented American multinational banking and financial services corporation and its senior executive in federal criminal trial involving more than $100 million in victim bank losses.
  • Represented public company in cross-border internal investigation into potential books and records and internal controls violations.
  • Conducted internal investigation for multi-billion dollar company into allegations of kickbacks, bid rigging, and breach of fiduciary duties.
  • Represented corporate victim before the United States Attorney’s Office in criminal theft of trade secrets case.
  • Designed and implemented multiple FCPA corporate compliance programs and provided company-wide training on the FCPA.
  • Defended 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 DOJ declining to bring criminal charges and SEC resolving the case on favorable terms.
  • Defended a Fortune 200 company against criminal allegations of price manipulation in the natural gas market relating to the California energy crisis. Negotiated $50 million DPA with the Department of Justice and the United States Attorney’s Office for the Northern District of California.
  • Represented major insurer in $90 million arbitration of cross-border loans and political risk insurance and obtained favorable settlement for client.

Featured Matters as a Federal Prosecutor

  • 2015:  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 $188 million.
  • 2015:  Convicted one of the nation’s “Top 10 Most Wanted” mortgage fraud defendants as part of a long-term undercover fraud investigation.
  • 2014:  Led the prosecution of Chicago’s historic “Silk Road” case and convicted the world’s largest online drug trafficker on Silk Road, described then by the government as the most sophisticated and extensive criminal marketplace of its kind on the Internet.
  • 2014:  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.
  • 2013:  Investigated and prosecuted the largest international criminal trade fraud, food fraud and corporate social responsibility cases in U.S. history, the first in 2010 at nearly $80 million, and the second series in 2013 at nearly $180 million, for a total of approximately $260 million.

JD, University of Virginia School of Law

B.S., Virginia Tech, in-honors summa cum laude
Phi Beta Kappa

Professional Memberships
  • International Association of Independent Corporate Monitors, Board Member (2015 – present)
  • American Law Institute, Member (2015 – present)
  • American Bar Foundation, Fellow (2014 – present)
  • ABA Criminal Justice Section Council, Voting Member (2013 – present); Advisor to the Council (2012 – 2013)
  • ABA Criminal Justice Section Global Anti-Corruption Committee, Co-Founder & National Co-Chair (2010 – present)
  • ABA International Law Section, Corporate Social Responsibility Committee, Senior Advisor (2013 – present)
  • ABA Task Force on College Due Process Rights and Victim Protection, National Chair (2016 - present)
  • ABA Criminal Justice Section CLE Board Membership, Board Member (2014 – present)
  • ABA Section Officers Conference (SOC) Annual Meeting Task Force, Representative (2012 – 2013)
  • Bloomberg BNA Criminal Law Reporter and White Collar Crime Report, Advisory Board Member (2010 – present)
  • Chicago Crime Commission, Member (2016 – present)
  • Federal Law Enforcement Officers Association – Chicago Chapter, Chief Business Officer & Board Member (2014 – 2016); Associate Member (2012 – present)
  • Mitchell A. Mars Foundation, Board Member (2014 – present)
  • ABA National Institute on Int’l Regulation & Compliance:  FCPA, Economic Sanctions & Export Control, Institute Chair (2013 – 2014)
  • ABA Conference Planning Committees
    • Ninth Annual Criminal Justice Section Fall Institute, Planning Committee Member (2016)
    • Global White Collar Crime Institute (Shanghai), Planning Committee Member (2014 – 2015)
    • Sixth Annual National Institute on the FCPA, Planning Committee Member (2013)
    • Fifth Annual National Institute on the FCPA, Planning Committee Member (2012)
  • University of Chicago Law School Corporate Lab, Advisor to the Lab (2011 – present)
  • University of Chicago Law School Legal Forum on Combating Corruption Symposium, Faculty Leader (2011)
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