Jacqueline C. Wolff
Jacqueline Wolff is a senior counsel in the Firm’s Investigations and White Collar Defense practice, a member of the financial services team and resident in the New York office. For more than 30 years, she has successfully defended companies and individuals accused of white collar crimes and False Claims Act (FCA) violations. A former federal prosecutor in the Frauds Division of the U.S. Attorney’s Office for the District of New Jersey, Jacqueline focuses her practice on defending individuals and companies before the U.S. Department of Justice (DOJ) and the Securities and Exchange Commission (SEC) in investigations of fraud-based crimes, most often in the financial services, health care and life sciences industries. She has also successfully defended multiple clients in FCA cases resulting in declinations from the government, resolutions as overpayment cases and, where the government decided not to intervene, outright dismissals of the qui tam. Jacqueline has also represented corporate clients ranging from Fortune 100 companies to small venture capital firms in Foreign Corrupt Practices Act (FCPA) investigations and worked with these clients to create and improve existing FCPA and anti-corruption compliance programs.
While in the U.S. Attorney’s Office, Jacqueline received numerous awards, including from the U.S. Nuclear Regulatory Commission, U.S. Immigration and Naturalization Service, U.S. Environmental Protection Agency (EPA) and Attorney General of the United States.
Jacqueline writes regularly for and is on the Editorial Board of the Business Crimes Bulletin, and she serves on the New York Regional Leadership Council for Brady United.
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Jacqueline C. Wolff
Jacqueline Wolff is a senior counsel in the Firm’s Investigations and White Collar Defense practice, a member of the financial services team and resident in the New York office. For more than 30 years, she has successfully defended companies and individuals accused of white collar crimes and False Claims Act (FCA) violations. A former federal prosecutor in the Frauds Division of the U.S. Attorney’s Office for the District of New Jersey, Jacqueline focuses her practice on defending individuals and companies before the U.S. Department of Justice (DOJ) and the Securities and Exchange Commission (SEC) in investigations of fraud-based crimes, most often in the financial services, health care and life sciences industries. She has also successfully defended multiple clients in FCA cases resulting in declinations from the government, resolutions as overpayment cases and, where the government decided not to intervene, outright dismissals of the qui tam. Jacqueline has also represented corporate clients ranging from Fortune 100 companies to small venture capital firms in Foreign Corrupt Practices Act (FCPA) investigations and worked with these clients to create and improve existing FCPA and anti-corruption compliance programs.
While in the U.S. Attorney’s Office, Jacqueline received numerous awards, including from the U.S. Nuclear Regulatory Commission, U.S. Immigration and Naturalization Service, U.S. Environmental Protection Agency (EPA) and Attorney General of the United States.
Jacqueline writes regularly for and is on the Editorial Board of the Business Crimes Bulletin, and she serves on the New York Regional Leadership Council for Brady United.
Experience
- Represented a multinational company in an FCPA investigation involving the president of an African country, with no charges being brought.
- Represented a FinTech company in an SEC investigation resulting in a declination.
- Representing a cryptocurrency trader in connection with various investigations of third parties by the Department of Justice.
- Represented a Fortune 100 company in a Department of Justice and SEC investigation into alleged FCPA violations, resulting in a non-prosecution agreement (NPA) for the parent company.
- Represented a foreign bank in connection with a Department of Justice offshore tax compliance investigation, resulting in a deferred prosecution agreement (DPA).
- Represented a hospital system in an FCA investigation by the U.S. Attorney’s Office for the Southern District of New York, resulting in a declination.
- Represented a pharmaceutical company in an False Claims Act qui tam, resulting in dismissal of the case.
- Represented a clinical laboratory company in an False Claims Act investigation by a U.S. Attorney, resulting in a negotiated overpayment settlement.
- Represented an investment advisor in an SEC investigation that resulted in a cease and desist order with no admission of liability.
- Represented a digital tech company in an SEC investigation into internal control over financial reporting that resulted in a cease and desist order with no admission of liability.
- Represented a construction company in an immigration investigation by U.S. Immigration and Customs Enforcement and the Department of Justice resulting in an NPA.
- Represented a large pharmaceutical company in a Department of Justice and OIG investigation relating to sales and marketing practices and concluding in a DPA.
- Represented officers of an international investment advisor in an SEC investigation into securities fraud.
- Represented officers of a multinational oil drilling corporation in a Department of Justice and SEC investigation into FCPA violations.
- Represented a bank officer in one of the Swiss bank investigations by the Department of Justice.
- Represented individuals in the Libor and Fx Trading investigations; no charges were brought.
- Advised a national insurance company on potential litigation risks in connection with a subsidiary's sale and distribution of opioids ahead of the merger with that subsidiary.
- Conducted an internal investigation into a pharmaceutical company’s interactions with physicians and designed a compliance program to address weaknesses in internal controls.
- Assisted dozens of multinational companies in conducting due diligence into potential FCPA and global anti-corruption violations by target companies and advised on the intended acquisitions.
- Designed FCPA and global anti-corruption compliance programs for multinational entities as well as private equity and venture capital firms.
Accomplishments
Panelist, “Current Events in Crypto Regulation and Enforcement: What You Need to Know About the Law Before You Do Anything (Else),” SuperCrowd 2023.
Speaker, “Climate Change Risk and Disclosure: A New Focus for SEC Enforcement,” Law Journal Newsletters, October 13, 2022.
Speaker, “Blockchain Tokenomics and Cryptocurrencies: Latest developments,” Alternative Finance Summit 2022: Fintech, Blockchain and Crowdfunding, Practising Law Institute, September 21, 2022.
Speaker, “The JOBS Act Nine Years Out: Washington and State House Developments in Crowdfunding and Alternative Finance,” Alternative Finance Summit 2021: Fintech, Blockchain and Crowdfunding, Practising Law Institute, September 22, 2021.
Speaker, “The JOBS Act Eight Years Out: Washington and State House Developments in Crowdfunding and Alternative Finance,” Alternative Finance Summit 2020: Marketplace Lending, Cryptocurrency and Crowdfunding, Practising Law Institute, September 10, 2020.
Speaker, “Operationalizing Your Global Compliance Program: A Pragmatic Approach – Dovetailing Your Program with the Company’s Overall Business Strategy,” Forum on FCPA and Anti-Corruption for the Life Sciences Industry, American Conference Institute, June 17, 2020. *Event postponed due to COVID-19
Speaker, “The JOBS Act Seven Years Out: Washington and State House Developments in Crowdfunding and Alternative Finance,” Alternative Finance Summit 2019: Marketplace Lending, Cryptocurrency and Crowdfunding, Practising Law Institute, August 5, 2019.
Speaker, “Government Investigations and Enforcement in the Financial Services Industry: What’s New?,” Bloomberg Next Webinar, September 25, 2018.
Speaker, “Responding to Government Investigations and Protecting Employers from Immigration-Related Penalties,” PLI's 49th Annual Immigration and Naturalization Institute, December 7, 2016.
Speaker, “Fraud and Abuse 2016: Game-Changing Trends and Cases (and How to Protect Your Organization),” BNA Webinar, November 10, 2015.
Speaker, “FCPA: Testing Your Compliance Plan Proactively,” Global Secure Summit Dining Club, June 12, 2014.
Speaker, “Minimizing FCPA Risk Exposure in Majority, Minority and Contractual Joint Ventures”, American Conference Institute’s 30th National Conference On The Foreign Corrupt Practices Act, May 2014.
Speaker, “Minimizing FCPA Risk Exposure in Majority, Minority and Contractual Joint Ventures”, American Conference Institute’s 29th National Conference On The Foreign Corrupt Practices Act, April 2013.
Speaker, “Creating a Home for the Whistleblower: How to Facilitate Open Communication and Appropriately Respond to Allegations in a Bounty Hunter Environment,” 28th National Conference on Foreign Corrupt Policy Act, November 15, 2012, Washington, D.C.
Speaker, “Corporate Internal Investigations: Nuts, Bolts and Special Problems, including the Attorney-Client Privilege,” Rutgers School of Law, September 2012.
Speaker, "FCPA: Hot Topics in Enforcement, Trends and Compliance Expectations," National Association of Women Lawyers 7th Annual General Counsel Institute, New York, NY, November 3–4, 2011.
Speaker, "Developing Internal Controls to Manage & Monitor Interactions with Health Care Practitioners & Regulators at All Levels of the Organization," Marcus Evans Life Sciences Strategies for Anti-Corruption & FCPA Compliance Conference, June 22–24, 2011.
Speaker, "Blowing the Whistle: How the SEC’s Plan Might Play Out," Institutional Investor Legal Forum Winter Roundtable, New York, NY, February 1, 2011.
Interview, "How to Size Up, and Manage, FCPA Investigation Costs," Compliance Week, August 17, 2010.
Speaker, "Clinical Trials: Minimizing Potential FCPA Risks When Conducting Global Trials Conference," FCPA and International Anti-Corruption for the Pharmaceutical and Medical Device Industries, New York, NY, April 28, 2009.
Speaker, "Voluntary Disclosures: Criteria to Determine When to Disclose, or Not," American Conference Institute’s National Conference on the Foreign Corrupt Practices Act, Washington, D.C., November 19, 2008.
Speaker, "Privacy and Ethical Issues in Internal Investigations," ACI Conducting & Responding to Investigations Conference, New York, NY, April 24, 2007.
Speaker, "BMS: A Case Study," ACI Corporate Governance Conference, New York, NY, January 19, 2006.
Chambers USA, Top-Ranked Attorney, Litigation: White Collar Crime and Government Investigations (New York), 2024
Bronze Medal, U.S. Environmental Protection Agency
Special Commendation, Attorney General of the United States
New York Super Lawyers, 2007–2022
The Best Lawyers in America, 2017–2025
White Collar Crime Expert Guides, 2020–2021
Admitted to practice in the state of New York, Southern District of New York, Eastern District of New York and United States Supreme Court
Member, New York Council of Defense Lawyers
Member, Board of Editors, Business Crimes Bulletin
Member, Women in White Collar Defense Association
Member, New York Regional Leadership Council, The Brady Center to Prevent Gun Violence
Member, Advisory Board, Bloomberg BNA’s Pharmaceutical Law & Industry Report
Member, Bechdel
Member, Women in Crypto
Former Member, Law360 White Collar Editorial Advisory Board
Quoted, “The DOJ Announces Intention to Launch Whistleblower Program: What Does It Mean for Whistleblowers?,” Anti-Corruption Report, April 10, 2024.
Quoted, “The DOJ Announces Intention to Launch Whistleblower Program: What Will It Look Like?,” Anti-Corruption Report, March 27, 2024.
Quoted, “Fifth Circuit’s Rafoi Bleuler Decision Underscores Extraterritorial Reach of FCPA and Money Laundering Law,” Anti-Corruption Report, April 26, 2023.
Author, “The Criminal Division’s Enforcement Policy: What’s New for Companies Deciding Whether to Voluntarily Disclose?,” Business Crimes Bulletin, March 1, 2023.
Co-author, “DOJ's Revised Corporate Prosecutions Policy: Deputy Attorney General Lisa Monaco's September 2022 Memorandum Ups the Ante,” Law.com, November 1, 2022.
Author, “Climate Change Risk and Disclosure: A New Focus for SEC Enforcement,” Law.com, June 16, 2022.
Co-author, “Disclosure of Investigations: Whether and When for Public Companies,” Law Journal Newsletters' Business Crimes Bulletin,” November 1, 2021.
Co-author, “Telehealth: The Wave of the Future for Both Medicine and Enforcement,” Law Journal Newsletters’ Business Crimes Bulletin, May 3, 2021.
Quoted, “Petrobras Denouement: Fixer Zwi Skornicki Gets Probation and a $50K Fine from the E.D.N.Y.,” Anti-Corruption Report, September 16, 2020.
Author, “The Updated FCPA Resource Guide,” Law Journal Newsletters’ Business Crimes Bulletin, September 1, 2020.
Co-author, “Conducting Internal Investigations During the COVID-19 Pandemic,” Law Journal Newsletters’ Business Crimes Bulletin, March 25, 2020.
Co-author, “Crowdfunding, Reg D and Reg A,” Law Journal Newsletters, October 2019.
Quoted, “The Anti-Corruption Report’s Guide to Risk Assessments: Where to Look for Risk and Risk Ranking,” Anti-Corruption Report, September 4, 2019.
Quoted, “The Anti-Corruption Report’s Guide to Risk Assessments: Techniques and Building a Team,” Anti-Corruption Report, August 7, 2019.
Quoted, “The Anti-Corruption Report’s Guide to Risk Assessments: Types of Assessments,” Anti-Corruption Report, June 26, 2019.
Author, “FCA Cases: Convincing DOJ to Move to Dismiss,” Law Journal Newsletters Business Crime Bulletin, April 2019.
Author, “Are Allegations of Lack of Medical Necessity in False Claims Act Cases a Basis for Settlement or Trial?” Law Journal Newsletters Business Crime Bulletin, October 2018.
Co-Author, “America’s Opioid Crisis,” Bloomberg BNA’s Pharmaceutical Law & Industry Report, March 30, 2018.
Co-author, “The National Opioid Epidemic: The Emergence of a Multi-Layer Approach,” Law Journal Newsletters, February 1, 2018.
Author, “Criminal Immigration Enforcement vs. Employers: Will It Be the New Normal?” Law Journal Newsletters Business Crime Bulletin, February 2017.
Co-author, “FCPA and AML Enforcement Review — ‘Follow the Money’: Liberty Reserve Case,” Payments Compliance, March 2, 2016.
Quoted, “Lack of Training and Due Diligence Leads to $19 Million Penalty for Hitachi,” The FCPA Report, October 7, 2015.
Author, “Pharmaceutical Industry: Guarding Against Bribery When Conducting Clinical Trials Overseas,” The FCPA Report, August 19, 2015.
Quoted, “When and How Should Companies Include Audit Rights in Third-Party Contracts?” The FCPA Report, August 20, 2014.
Quoted, “When and How Should Companies Include Audit Rights in Third-Party Contracts?” The FCPA Report, August 6, 2014.
Quoted, “A Guide to Anti-Corruption Representations in Third-Party Contracts: Clauses for High-Risk Situations and Enforcement Strategies,” The FCPA Report, July 9, 2014.
Co-author, “General Schemes vs. Specific Claims: The Ongoing Circuit Split over Fraud and the False Claims Act,” Law Journal Newsletters Business Crimes Bulletin, July, 2014.
Author, “General Schemes vs. Specific Claims; The Ongoing Circuit Split over Fraud and the False Claims Act,” Business Crimes Bulletin, July 1, 2014.
Interviewee, “FCPA Training That Works: An Interview with Jacqueline C. Wolff,” The FCPA Report, May 2013.
Co-Author, “The New FCPA Guidance: DOJ and SEC's Views on Hospitality, Instrumentalities, Successor Liability, and Compliance,” Manatt Corporate Investigations Newsletter, November 2012.
Co-Author, “DOJ Escalates Use of the Foreign Corrupt Practices Act To Seize Customer Bank Accounts”, BankNews, October 2012.
Co-Author, "Is Anyone Not a Foreign Official Under the FCPA?" Business Crimes Bulletin, February 2011.
Co-Author, "Health Care Reform, or 'Qui Tams Made Easy,'" Business Crimes Bulletin, June 2010.
Co-Author, "Law Firm Files: When the 'Client' Demanding Them Is Not the Client Who Hired You," Business Crimes Bulletin, October 2009.
Co-Author, "FCPA Due Diligence and Data Privacy Laws," Business Crimes Bulletin, November 2008.
Co-Author, "Deferred Prosecution Agreements and Privileged Documents," Business Crimes Bulletin, November 2007.
Co-Author, "Liability Under the Foreign Corrupt Practices Act," The Review of Securities & Commodities Regulation, January 2007.
Co-Author, "Liability of U.S. Companies for Alleged Bribery by Foreign Subsidiaries," Law Journal Newsletters, August 2005.
Fordham University School of Law, J.D.
Dean’s List with Distinction, Fordham Law Review
University of Pennsylvania, B.A., Biology/Sociology
Related Practices
Services
Fintech
Litigation
Investigations, Compliance and White Collar Defense
False Claims Act
Financial Services Litigation and Enforcement
Blockchain and Cryptocurrency
Antitrust and Competition
Industries
Manatt Health
Manatt Financial Services
Climate Change and Clean Energy
