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Litigation

Investigations and Regulatory Enforcement

Investigations and Regulatory Enforcement

Cravath is a trusted advisor to the world’s leading companies, their boards of directors and senior executives in the full range of corporate crises, regulatory enforcement proceedings and white collar criminal defense matters. Our reach in the white collar arena is global, extending to cross‑border issues involving Asia, Africa, the Middle East, Europe and the Americas for clients in diverse industries. 

We regularly lead complex internal investigations, based on company initiative and in response to whistleblower claims and shareholder demands, and guide companies through sensitive government investigations. Known as trial-ready attorneys, we also defend our clients in parallel or related regulatory or civil proceedings that can arise from investigations. Boards of directors and their executives turn to us for advice on corporate governance, corporate transaction risks, potential areas of exposure and preventive measures to help deter regulatory intervention and lawsuits. We also perform compliance risk assessments and design compliance programs that meet DOJ and SEC standards. Our practice extends to defending board members, senior executives and other individuals in investigations and related litigation.

Our experience runs the gamut. Our team has handled three of the most complex multi-agency, multi‑country investigations on the public record, two of which involved alleged violations of the Foreign Corrupt Practices Act. Domestic and international clients rely on our prompt and practical counsel on trade and economic sanctions and export controls to run their businesses. We also investigate and advise clients on digital assets; the FCPA; accounting and disclosure issues; environmental, social and governance (ESG) matters; insider trading; tax evasion; potential executive misconduct; securities fraud; money laundering and anti‑money laundering controls; healthcare fraud; and criminal antitrust matters. In addition, as the legal landscape undergoes rapid change in the wake of increasingly complex cybersecurity technology, our team of Cybersecurity & Data Privacy attorneys are poised to address the full range of our clients’ cyber‑related concerns.

The hallmark of our Investigations and Regulatory Enforcement Practice is our interdisciplinary approach to solving our clients’ problems. Our team of seasoned litigators and corporate advisory attorneys includes senior U.S. Department of Justice officials, senior SEC lawyers and prosecutors from the U.S. Attorney’s Office for the Southern and Eastern Districts of New York. We bring that experience to bear when advising clients in the boardroom and defending them before domestic and foreign government agencies and in courtrooms nationwide.

Since its inception, Cravath’s Investigations and Regulatory Enforcement practice has been ranked among the top in the nation, with The Legal 500 US calling us a “go‑to firm for handling government and internal investigations, regulatory compliance and white‑collar defense.” Cravath is recognized as a leading firm for its Investigations and Regulatory Enforcement practice by Benchmark Litigation, Chambers Global, Chambers USA, Global Investigations Review, The Legal 500 US and Best Lawyers Best Law Firms. We have also been named a Law360 “Practice Group of the Year” in Compliance and received the Gold Award for Best U.S. Law Firm for Investigations & White Collar by the International Legal Alliance Summit & Awards. Our “strong bench of criminal defense attorneys” and “strength in handling investigations and litigation involving securities fraud and anti‑corruption matters” set us apart. (Chambers USA) 

Our attorneys have earned repeat praise from clients and the market, including:

  • “It’s a powerhouse. It’s a bet-the-company firm – if you have a real problem, go to Cravath.” Client, Chambers USA
  • “They are best of the best when it comes to skill level. They have a great deal of credibility, are able to guide and help the client with a steady hand, and provide a deliberate and strategic approach.” Chambers USA
  • “They are very comprehensive, well-structured and can guide company through various and different parts of an investigation.” Chambers Global
  • “Their lawyering is excellent,” and “they bring a level of sophistication coupled with a lot of common sense and a practical approach.” Client, Chambers USA
  • Cravath’s team is “succinct, refined, user-friendly, and very well-versed in the ways of the regulators.” Client, The Legal 500 US
  • “They present great value for the money, a quick understanding of clients’ needs and dilemmas, and around the clock availability.” Client, Chambers USA
  • “They are very smart, and don’t take a one-size-fits-all approach—they really tailor the extent and scope to the specific questions under review.” Client, Chambers USA

We regularly lead complex internal investigations, based on company initiative and in response to whistleblower claims and shareholder demands, and guide companies through sensitive government investigations. Known as trial-ready attorneys, we also defend our clients in parallel or related regulatory or civil proceedings that can arise from investigations. Boards of directors and their executives turn to us for advice on corporate governance, corporate transaction risks, potential areas of exposure and preventive measures to help deter regulatory intervention and lawsuits. We also perform compliance risk assessments and design compliance programs that meet DOJ and SEC standards. Our practice extends to defending board members, senior executives and other individuals in investigations and related litigation.

Our experience runs the gamut. Our team has handled three of the most complex multi-agency, multi‑country investigations on the public record, two of which involved alleged violations of the Foreign Corrupt Practices Act. Domestic and international clients rely on our prompt and practical counsel on trade and economic sanctions and export controls to run their businesses. We also investigate and advise clients on digital assets; the FCPA; accounting and disclosure issues; environmental, social and governance (ESG) matters; insider trading; tax evasion; potential executive misconduct; securities fraud; money laundering and anti‑money laundering controls; healthcare fraud; and criminal antitrust matters. In addition, as the legal landscape undergoes rapid change in the wake of increasingly complex cybersecurity technology, our team of Cybersecurity & Data Privacy attorneys are poised to address the full range of our clients’ cyber‑related concerns.

The hallmark of our Investigations and Regulatory Enforcement Practice is our interdisciplinary approach to solving our clients’ problems. Our team of seasoned litigators and corporate advisory attorneys includes senior U.S. Department of Justice officials, senior SEC lawyers and prosecutors from the U.S. Attorney’s Office for the Southern and Eastern Districts of New York. We bring that experience to bear when advising clients in the boardroom and defending them before domestic and foreign government agencies and in courtrooms nationwide.

Since its inception, Cravath’s Investigations and Regulatory Enforcement practice has been ranked among the top in the nation, with The Legal 500 US calling us a “go‑to firm for handling government and internal investigations, regulatory compliance and white‑collar defense.” Cravath is recognized as a leading firm for its Investigations and Regulatory Enforcement practice by Benchmark Litigation, Chambers Global, Chambers USA, Global Investigations Review, The Legal 500 US and Best Lawyers Best Law Firms. We have also been named a Law360 “Practice Group of the Year” in Compliance and received the Gold Award for Best U.S. Law Firm for Investigations & White Collar by the International Legal Alliance Summit & Awards. Our “strong bench of criminal defense attorneys” and “strength in handling investigations and litigation involving securities fraud and anti‑corruption matters” set us apart. (Chambers USA) 

Our attorneys have earned repeat praise from clients and the market, including:

  • “It’s a powerhouse. It’s a bet-the-company firm – if you have a real problem, go to Cravath.” Client, Chambers USA
  • “They are best of the best when it comes to skill level. They have a great deal of credibility, are able to guide and help the client with a steady hand, and provide a deliberate and strategic approach.” Chambers USA
  • “They are very comprehensive, well-structured and can guide company through various and different parts of an investigation.” Chambers Global
  • “Their lawyering is excellent,” and “they bring a level of sophistication coupled with a lot of common sense and a practical approach.” Client, Chambers USA
  • Cravath’s team is “succinct, refined, user-friendly, and very well-versed in the ways of the regulators.” Client, The Legal 500 US
  • “They present great value for the money, a quick understanding of clients’ needs and dilemmas, and around the clock availability.” Client, Chambers USA
  • “They are very smart, and don’t take a one-size-fits-all approach—they really tailor the extent and scope to the specific questions under review.” Client, Chambers USA
  • Deals & Cases
  • Recent News & Insights

Deals & Cases

January 23, 2025

SEC Closes Investigation into Eros Media World plc and Affiliates; Internal Investigation Reveals No Wrongdoing

On January 22, 2025, Eros Media World plc, a global media and entertainment company, announced that its internal review of certain accounting practices and internal controls has been concluded, with the Audit Committee determining that no revenues of the Company recognized during the fiscal year ended March 31, 2020, were inappropriately recognized, and finding no impairment in the intangible assets and goodwill reflected on the Company’s Form 6‑K dated March 31, 2021. In addition, the Audit Committee found no material weaknesses in internal controls over financial reporting.

Deals & Cases

July 09, 2024

Silvergate’s Settlement Agreements with the Federal Reserve, California Department of Financial Protection and Innovation and Securities and Exchange Commission

On July 1, 2024, Silvergate announced it has agreed to settlements with the Board of Governors of the Federal Reserve System (“Federal Reserve”), the California Department of Financial Protection and Innovation (“DFPI”) and the Securities and Exchange Commission (“SEC”). In a statement, Silvergate noted its decision to liquidate voluntarily and without government assistance in March 2023, and that, as of November 2023, all deposits had been repaid to banking customers, soon after which Silvergate ceased banking operations. The announced settlements, which facilitate the surrender of Silvergate’s bank charter, are part of the Bank’s continued orderly wind down and conclude investigations by the Federal Reserve, DFPI, and SEC. Cravath represented Silvergate in connection with the investigations, resulting settlements, and voluntary liquidation.

Deals & Cases

February 14, 2024

State Street Corporation’s $1.5 Billion Offering of Depositary Shares

Cravath represented the underwriters in connection with the $1.5 billion offering of depositary shares representing preferred stock of State Street Corporation, a provider of a broad range of financial products and services to institutional investors worldwide. The transaction closed on January 31, 2024.

Deals & Cases

January 11, 2024

AerCap’s Over $1.2 Billion in Insurance Recoveries

AerCap Holdings N.V, the world’s largest commercial aircraft leasing company, which Cravath is representing in connection with U.S. sanctions and export controls matters, has secured over $1.2 billion in related insurance recoveries involving Russian airlines’ refusal to return over 100 aircraft leased from AerCap following Russia’s invasion of Ukraine in February 2022. In September 2023, in the first announced insurance settlement of its kind, Cravath represented AerCap in obtaining authorizations from the U.S. Office of Foreign Assets Control (“OFAC”) and the U.S. Department of Commerce’s U.S. Bureau of Industry and Security (“BIS”) for an agreement to enable payment of approximately $645 million to AerCap to resolve claims against certain Russian insurers and airlines as to a substantial number of AerCap aircraft. Cravath also represented AerCap before BIS and OFAC in connection with AerCap’s subsequent, $572 million insurance settlements with Russian insurers and airlines announced in December 2023.

Deals & Cases

December 20, 2023

Aon’s $13.4 Billion Acquisition of NFP

On December 20, 2023, Aon plc (“Aon”), a leading global professional services firm, announced the signing of a definitive agreement to acquire NFP, a leading middle‑market property and casualty broker, benefits consultant, wealth manager and retirement plan advisor, from funds affiliated with NFP’s main capital sponsor, Madison Dearborn Partners, and funds affiliated with HPS Investment Partners. Under the terms of the transaction, Aon will acquire NFP for a total consideration estimated to be $13.4 billion at the time of close, which will be funded by $7 billion of cash and $6.4 billion of Aon stock. Cravath is representing Aon in connection with the transaction.

Activities

May 02, 2025

Cravath Partners Named to Lawdragon’s 2025 List of Leading Global Cyber Lawyers

On May 2, 2025, Cravath partners David J. Kappos, John D. Buretta, Noah Joshua Phillips, Sasha Rosenthal‑Larrea, Evan Norris, Michael L. Arnold and Kimberley S. Drexler were named to Lawdragon’s list of “500 Leading Global Cyber Lawyers” in recognition of their work advising clients on incident response and preparation, corporate governance and disclosure matters, investigations and regulatory enforcement, and transactional and competition matters related to data privacy and cybersecurity. The list recognizes “world leaders in privacy, data, security, incident response, and the deals and lawsuits that revolve around all things Cyber.”

Publications

April 16, 2025

DOJ Announces New Digital Asset Enforcement Priorities

On April 15, 2025, Cravath prepared a memo for its clients entitled “DOJ Announces New Digital Asset Enforcement Priorities.” The memo examines the Office of the Deputy Attorney General’s recently issued memorandum with the subject “Ending Regulation By Prosecution,” which sets out new enforcement priorities for digital asset‑related investigations and prosecutions by the U.S. Department of Justice.

Activities

March 21, 2025

Evan Norris Speaks at ICC Mexico and Anticorruption Commission’s IX Anticorruption Postgraduate Course

On March 18, 2025, Cravath partner Evan Norris participated in the International Chamber of Commerce Mexico and the Anticorruption Commission’s IX Anticorruption Postgraduate Course, hosted in collaboration with Universidad Panamericana. The course brought together high‑level government officials, legal scholars and practitioners for sessions on combatting national and global corruption. Evan’s session focused on developments in U.S. criminal enforcement in sports.

Activities

March 17, 2025

Nicole Argentieri Speaks at the American Bar Association’s 40th White Collar Crime Institute

On March 5, 2025, Cravath partner Nicole M. Argentieri participated in the American Bar Association’s 40th White Collar Crime Institute, which was held from March 4‑7 in Miami. The event convened federal and state judges and prosecutors, SEC and CFTC leadership, defense attorneys, corporate in‑house counsel and members of the academic community to discuss hot topics in white‑collar crime. Nicole spoke on a panel entitled “International – New Trends in Resolving Cross Border Investigations in Europe and South America,” which explored key developments in the international white collar crime scene, including regarding international cooperation and non‑trial resolutions.

Activities

March 14, 2025

John Buretta Moderates Panel at GIR Live’s Annual Investigations Meeting DC 2025

On March 13, 2025, Cravath partner John D. Buretta participated in Global Investigations Review Live’s Annual Investigations Meeting DC 2025, which was held in Washington, D.C. John moderated a panel entitled “Promoting Company Compliance: Corporate Culture and Compensation,” which reviewed how companies are approaching legal compliance in 2025, including areas that pose the greatest compliance challenges.

Deals & Cases

January 23, 2025

SEC Closes Investigation into Eros Media World plc and Affiliates; Internal Investigation Reveals No Wrongdoing

On January 22, 2025, Eros Media World plc, a global media and entertainment company, announced that its internal review of certain accounting practices and internal controls has been concluded, with the Audit Committee determining that no revenues of the Company recognized during the fiscal year ended March 31, 2020, were inappropriately recognized, and finding no impairment in the intangible assets and goodwill reflected on the Company’s Form 6‑K dated March 31, 2021. In addition, the Audit Committee found no material weaknesses in internal controls over financial reporting.

Deals & Cases

July 09, 2024

Silvergate’s Settlement Agreements with the Federal Reserve, California Department of Financial Protection and Innovation and Securities and Exchange Commission

On July 1, 2024, Silvergate announced it has agreed to settlements with the Board of Governors of the Federal Reserve System (“Federal Reserve”), the California Department of Financial Protection and Innovation (“DFPI”) and the Securities and Exchange Commission (“SEC”). In a statement, Silvergate noted its decision to liquidate voluntarily and without government assistance in March 2023, and that, as of November 2023, all deposits had been repaid to banking customers, soon after which Silvergate ceased banking operations. The announced settlements, which facilitate the surrender of Silvergate’s bank charter, are part of the Bank’s continued orderly wind down and conclude investigations by the Federal Reserve, DFPI, and SEC. Cravath represented Silvergate in connection with the investigations, resulting settlements, and voluntary liquidation.

Deals & Cases

February 14, 2024

State Street Corporation’s $1.5 Billion Offering of Depositary Shares

Cravath represented the underwriters in connection with the $1.5 billion offering of depositary shares representing preferred stock of State Street Corporation, a provider of a broad range of financial products and services to institutional investors worldwide. The transaction closed on January 31, 2024.

Deals & Cases

January 11, 2024

AerCap’s Over $1.2 Billion in Insurance Recoveries

AerCap Holdings N.V, the world’s largest commercial aircraft leasing company, which Cravath is representing in connection with U.S. sanctions and export controls matters, has secured over $1.2 billion in related insurance recoveries involving Russian airlines’ refusal to return over 100 aircraft leased from AerCap following Russia’s invasion of Ukraine in February 2022. In September 2023, in the first announced insurance settlement of its kind, Cravath represented AerCap in obtaining authorizations from the U.S. Office of Foreign Assets Control (“OFAC”) and the U.S. Department of Commerce’s U.S. Bureau of Industry and Security (“BIS”) for an agreement to enable payment of approximately $645 million to AerCap to resolve claims against certain Russian insurers and airlines as to a substantial number of AerCap aircraft. Cravath also represented AerCap before BIS and OFAC in connection with AerCap’s subsequent, $572 million insurance settlements with Russian insurers and airlines announced in December 2023.

Deals & Cases

December 20, 2023

Aon’s $13.4 Billion Acquisition of NFP

On December 20, 2023, Aon plc (“Aon”), a leading global professional services firm, announced the signing of a definitive agreement to acquire NFP, a leading middle‑market property and casualty broker, benefits consultant, wealth manager and retirement plan advisor, from funds affiliated with NFP’s main capital sponsor, Madison Dearborn Partners, and funds affiliated with HPS Investment Partners. Under the terms of the transaction, Aon will acquire NFP for a total consideration estimated to be $13.4 billion at the time of close, which will be funded by $7 billion of cash and $6.4 billion of Aon stock. Cravath is representing Aon in connection with the transaction.

Activities

May 02, 2025

Cravath Partners Named to Lawdragon’s 2025 List of Leading Global Cyber Lawyers

On May 2, 2025, Cravath partners David J. Kappos, John D. Buretta, Noah Joshua Phillips, Sasha Rosenthal‑Larrea, Evan Norris, Michael L. Arnold and Kimberley S. Drexler were named to Lawdragon’s list of “500 Leading Global Cyber Lawyers” in recognition of their work advising clients on incident response and preparation, corporate governance and disclosure matters, investigations and regulatory enforcement, and transactional and competition matters related to data privacy and cybersecurity. The list recognizes “world leaders in privacy, data, security, incident response, and the deals and lawsuits that revolve around all things Cyber.”

Publications

April 16, 2025

DOJ Announces New Digital Asset Enforcement Priorities

On April 15, 2025, Cravath prepared a memo for its clients entitled “DOJ Announces New Digital Asset Enforcement Priorities.” The memo examines the Office of the Deputy Attorney General’s recently issued memorandum with the subject “Ending Regulation By Prosecution,” which sets out new enforcement priorities for digital asset‑related investigations and prosecutions by the U.S. Department of Justice.

Activities

March 21, 2025

Evan Norris Speaks at ICC Mexico and Anticorruption Commission’s IX Anticorruption Postgraduate Course

On March 18, 2025, Cravath partner Evan Norris participated in the International Chamber of Commerce Mexico and the Anticorruption Commission’s IX Anticorruption Postgraduate Course, hosted in collaboration with Universidad Panamericana. The course brought together high‑level government officials, legal scholars and practitioners for sessions on combatting national and global corruption. Evan’s session focused on developments in U.S. criminal enforcement in sports.

Activities

March 17, 2025

Nicole Argentieri Speaks at the American Bar Association’s 40th White Collar Crime Institute

On March 5, 2025, Cravath partner Nicole M. Argentieri participated in the American Bar Association’s 40th White Collar Crime Institute, which was held from March 4‑7 in Miami. The event convened federal and state judges and prosecutors, SEC and CFTC leadership, defense attorneys, corporate in‑house counsel and members of the academic community to discuss hot topics in white‑collar crime. Nicole spoke on a panel entitled “International – New Trends in Resolving Cross Border Investigations in Europe and South America,” which explored key developments in the international white collar crime scene, including regarding international cooperation and non‑trial resolutions.

Activities

March 14, 2025

John Buretta Moderates Panel at GIR Live’s Annual Investigations Meeting DC 2025

On March 13, 2025, Cravath partner John D. Buretta participated in Global Investigations Review Live’s Annual Investigations Meeting DC 2025, which was held in Washington, D.C. John moderated a panel entitled “Promoting Company Compliance: Corporate Culture and Compensation,” which reviewed how companies are approaching legal compliance in 2025, including areas that pose the greatest compliance challenges.

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Celebrating 200 years of partnership. In 2019, we celebrated our bicentennial. Our history mirrors that of our nation. Integral to our story is our culture.

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