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Investigations & Compliance

WTO attorneys have successfully represented numerous sophisticated clients before a broad range of federal, state, and administrative agencies. Such clients include telecommunications companies, financial institutions, technology manufacturers and service providers, government contractors, healthcare providers and institutions, and medical device manufacturers.

WTO represents clients in the prevention or mitigation of enforcement actions and criminal investigations conducted by federal and state agencies. We are ever mindful of the intense public scrutiny such investigations may precipitate, and we take pains to maintain every discretion possible. WTO attorneys represent clients before professional licensure and review boards. Our clients include corporations, officers, directors, public officials, and service providers. We also provide legal representation to clients who are the targets of governmental investigations including in grand jury proceedings.

Our team helps prevent enforcement actions or criminal investigations by implementing compliance and remediation programs and internal safeguards. Where our internal investigations have revealed gaps in compliance procedures, we have successfully worked to amend administrative lapses and implement new policies, procedures, and safeguards to promote future compliance and avoid adverse actions. We also work with clients to self-disclose issues, when necessary or desirable, to minimize the potential impact of enforcement actions on businesses and employees.


  • Managed the global investigations, class action, and commercial litigation dockets for a Fortune 150 products manufacturer.
  • Successfully defended a manufacturing company against multiple government investigations of false advertising allegations related to the company's fastest growing product category.
  • Represented an oil and gas developer in responding to a multi-agency securities investigation involving the Securities Exchange Commission and several state securities boards and divisions.
  • Conducted an internal investigation for a Fortune 500 holding company for various life insurance companies and investment firms relating to a former employee's allegations of retaliation, discrimination and violations of the Securities Exchange Act.
  • Represented a defense service contractor in response to a Department of Justice investigation involving alleged Foreign Corrupt Practices Act violations.
  • Conducted an internal investigation of a hospital employee accused of sexually assaulting two patients in the recovery room following surgery.
  • Successfully defended a Fortune 50 telecommunications conglomerate against allegations brought by a competitor that WTO's client breached FCC phone number portability regulations.
  • Successfully represented a leading global chemical company in an investigation involving multiple federal agencies and international trade compliance issues.
  • Represented an individual physician in a criminal and civil health care fraud investigation. The United States declined to intervene in the civil qui tam action and no criminal charges were filed.
  • Conducted an internal investigation for a hospital into claims of sexual assault by an employee and advised the hospital concerning the criminal indictment and subsequent prosecution of the employee.
  • Conducted an investigation of a major national bank's foreign exchange program. Brought civil fraud action under FIRREA asserting claims of mail and wire fraud against the bank and an individual employee of the bank. Defeated the defendants' motions to dismiss the complaint. This was a case of first impression concerning the scope of FIRREA, and the court's opinion has since been followed by other judges.
  • Investigated a major FHA lender's mortgage lending and underwriting practices, and brought a civil fraud action under the FCA and FIRREA against the lender, its owner and CEO, and another senior employee. Defeated defendants' motions to dismiss the FCA and FIRREA claims.
  • Represent a stock transfer agent in securities fraud investigated by the United States.
  • Represent a federal contractor in a procurement integrity investigation.
  • Represent senior executives in a False Claims Act investigation involving allegations of fraud on defense agencies.
  • Led investigation of an explosion at a commercial facility that caused personal injuries and damages in excess of $4 million.
  • Defended a public company auditor at trial and on appeal in a proceeding brought by the United States Securities and Exchange Commission.
  • Successfully represented a university in a grand jury investigation regarding various school scandals.
  • Won a $4.2 million judgment for a renewable energy client involving an executive's embezzlement from the company.
  • Represented large multinational document services company and large accounting firm in connection with investigations by the U.S. Securities and Exchange Commission regarding alleged accounting irregularities.
  • Obtained summary judgment for Lockheed Martin with regard to the majority of potentially $2 billion in exposure in a major federal False Claims Act case in Idaho. Allegations included false claims associated with a contract for management of the U.S. Department of Energy facility in Idaho Falls, ID. Following summary judgment, the remainder of the case settled favorably.
  • Represented a private school following a sexual assault investigation.
  • Participated in an international electronic discovery investigation for a computer hardware manufacturer in response to investigations by the U.S. Department of Justice, the U.S. Federal Trade Commission, and the European Commission.
  • Conducted internal investigations of international private equity firm and large semiconductor manufacturer.
  • Represent a senior partner of a physicians group in a federal investigation into alleged healthcare fraud and related qui tam proceedings.
  • Represent the former CEO of a hospice care organization in a federal False Claims Act investigation and related qui tam litigation.
  • Represent a technology company under investigation for alleged conflict of interest charges in a government contract.
  • Represent a cloud-based healthcare recordkeeping service in Stored Communications Act and related compliance issues and grand jury proceedings.
  • Represented an originator and servicer of mortgage loans in multiple investigations conducted by the United States into allegations of mortgage and appraisal fraud.
  • Represented one of the nation's largest manufacturers of mobile home parts in allegations of corruption and regulatory noncompliance.
  • Represented an airline pilot in an investigation by the United States of crew intoxication.
  • Represented a prominent Colorado lawyer in an investigation by the State of Colorado involving allegations of securities fraud.
  • Represented a senior public official in corruption-related proceedings being investigated by the United States.


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