Charles S. Leeper

Partner

Washington

(202) 842-8877 phone
(202) 842-8465 fax

Charles S. Leeper is head of the firm’s White Collar Criminal Defense and Corporate Investigations Team and serves as a Managing Partner of the Firm. His practice focuses on the defense of white collar criminal investigations and prosecutions, congressional inquiries and related civil proceedings.

Charlie previously served as an Assistant U.S. Attorney for the District of Columbia, where he investigated and prosecuted an array of complex cases involving white collar offenses, public corruption, asset forfeiture, espionage and terrorism. Charlie also supervised a team of other veteran prosecutors in his capacity as Deputy Chief of the Special Prosecutions Unit.

Charlie has extensive experience defending companies and individuals against allegations of federal criminal violations and civil fraud offenses. The following are examples of successful representations of our clients in various industries who are subject to a wide range of regulatory regimes.

Antitrust. Obtained decisions from the Department of Justice Antitrust Division to decline prosecution in large-scale, criminal price-fixing or bid-rigging investigations on behalf of multiple clients.

Environmental. Obtained decisions from the Environment and Natural Resources Division of the Department of Justice to decline prosecution in Clean Water Act, Clean Air Act, and RCRA investigations of a variety of clients. 

Charlie is also representing a major oil and gas services company in connection with the investigation of the Deepwater Horizon explosion and oil spill.

Foreign Corrupt Practices Act. Following a four-month trial in the largest ever FCPA prosecution of individuals, obtained dismissal of all charges filed against an in-house attorney in the military products industry.

Obtained a decision from the Criminal Division of the Department of Justice to decline prosecution in an FCPA investigation of an insurance company based in a U.S. Territory with regard to financial transactions in Nigeria.

Conducted internal investigations of possible FCPA violations for clients in the electronic components, beverage, medical supply, and oil and gas services industries.

Public Contracts. Obtained decisions from the Criminal Division of the Department of Justice to decline prosecution in investigations of alleged corruption in the federal procurement process for contracts awarded to a variety of clients. 

Charlie also obtained a favorable settlement for a large privately-owned construction company sued by the United States under the federal False Claims Act, following a two-month trial and successful appeal that resulted in an adverse judgment being vacated.

Securities. Obtained decisions from the Criminal Division of the Department of Justice, and the U.S. Securities and Exchange Commission, to decline prosecution and/or the commencement of enforcement action in securities fraud investigations of numerous clients.

Ethics and Compliance. Counseled numerous clients on a variety of compliance issues implicating the FCPA, competition laws, and federal procurement requirements.

Prepared Ethical Conduct codes and rules for implementation by clients and distribution to employees.

Conducted training of client employees on various compliance and ethical conduct matters arising from the FCPA, competition laws, and federal procurement requirements.

Representative Matters

Antitrust:

  • A publicly held manufacturer of chemical analysis and measurement equipment;
  • A publicly held company in the oil and gas services industry;
  • A large privately owned construction company in connection with allegations of bid rigging on USAID-funded construction projects in Egypt;
  • The former CEO of a joint venture in the elastomers industry;
  • The COO of a major processor in the scrap metal industry;
  • The COO of a helicopter transport company;
  • A marketing executive for a leading manufacturer of ceramic proppants, an additive used in the oil and gas drilling services industry; and
  • A senior executive for a leading manufacturer in the automobile paint industry.

Environmental:

  • A large privately owned construction company in connection with allegations of CWA violations in the construction of a bridge in Tampa Bay;
  • A vice-president of a major chemical manufacturer; and
  • The CFO of a major coke producer.

Public Contracts:

  • Computer manufacturers that supplied equipment to the Federal Bureau of Investigation and the Drug Enforcement Administration; and
  • A major construction company serving as the prime contractor on federal courthouse construction projects.

Securities:

  • A publicly traded reinsurer in connection with allegations of insider trading;
  • Partners and associates in a major law firm in connection with DOJ and SEC investigations of off-balance sheet entities used by Enron;
  • Sales and marketing executives in connection with parallel criminal and civil investigations arising out of alleged improper revenue recognition in the internet services industry; and
  • The CFO of a major hedge fund in connection with DOJ and SEC investigations of alleged failure to disclose beneficial ownership of publicly traded securities.

Publications

10/31/2014
FCPA Bulletin
Layne Christensen Settles SEC FCPA Probe -- Negligible Evidence of Business Nexus Element May Explain DOJ Declination
5/22/2014
FCPA Bulletin
Esquenazi Opinion Extends Reach of FCPA, Adopting Broad Definition of “Instrumentality of a Foreign Government”
3/28/2014
FCPA Bulletin
Marubeni Plea Agreement Suggests There May Be More FCPA Charges to Come
10/1/2013
In-House Defense Quarterly
FCPA Article: Lessons from Litigated Cases
3/7/2013
Client Alert
SEC Speaks 2013: Enforcement Division Highlights Need for Strong Compliance Programs and Continued Efforts to Expand Reach of FCPA Investigations
6/25/2010
U.S. Supreme Court/White Collar Criminal Defense Alert
U.S. Supreme Court: Honest Services Fraud Limited to Bribes and Kickbacks - Defendant Need Not Acquiesce to Special Interrogatories to Jury to Preserve Appeal
1/22/2010
FCPA Alert
BLACKJACK: 21 Nabbed in Las Vegas in Largest Ever FCPA Sting Operation
4/11/2008
White Collar Crime Alert
Ten Myths of FCPA Compliance

Speaking Engagements

6/27/2013
DRI Government Enforcement and Corporate Compliance Conference
Recent Developments and Trial Strategy in Foreign Corrupt Practices Act Cases
6/4/2013
DELVACCA Litigation Institute
Managing FCPA Litigation Risks in Business Partnering Relationships
11/16/2010
ACI 24th Annual FCPA Conference
7/6/2008
NASFAA Annual Conference

Antitrust:

  • A publicly held manufacturer of chemical analysis and measurement equipment;
  • A publicly held company in the oil and gas services industry;
  • A large privately owned construction company in connection with allegations of bid rigging on USAID-funded construction projects in Egypt;
  • The former CEO of a joint venture in the elastomers industry;
  • The COO of a major processor in the scrap metal industry;
  • The COO of a helicopter transport company;
  • A marketing executive for a leading manufacturer of ceramic proppants, an additive used in the oil and gas drilling services industry; and
  • A senior executive for a leading manufacturer in the automobile paint industry.

Environmental:

  • A large privately owned construction company in connection with allegations of CWA violations in the construction of a bridge in Tampa Bay;
  • A vice-president of a major chemical manufacturer; and
  • The CFO of a major coke producer.

Public Contracts:

  • Computer manufacturers that supplied equipment to the Federal Bureau of Investigation and the Drug Enforcement Administration; and
  • A major construction company serving as the prime contractor on federal courthouse construction projects.

Securities:

  • A publicly traded reinsurer in connection with allegations of insider trading;
  • Partners and associates in a major law firm in connection with DOJ and SEC investigations of off-balance sheet entities used by Enron;
  • Sales and marketing executives in connection with parallel criminal and civil investigations arising out of alleged improper revenue recognition in the internet services industry; and
  • The CFO of a major hedge fund in connection with DOJ and SEC investigations of alleged failure to disclose beneficial ownership of publicly traded securities.