As sure as the sun rises in the east and dogs bark – and following a well traveled career path – the Assistant Chief of the DOJ’s FCPA Unit is joining a law firm for an FCPA practice.
According to this Akin Gump Strauss Hauer & Feld LLP release:
“Gerald Moody joins Akin from the U.S. Department of Justice (DOJ) Criminal Division’s Fraud Section, where he was an Assistant Chief of the Foreign Corrupt Practices Act (FCPA) Unit. During his time at the DOJ Fraud Section, Moody led or supervised more than 100 FCPA-related investigations. Moody coordinated regularly with counterparts at domestic and international law enforcement and regulatory agencies, including various U.S. Attorney’s Offices, the SEC, FinCEN and foreign authorities in the United Kingdom, Brazil, France, and Switzerland, among others.”
In the release, Akin chairperson Kim Koopersmith states:
“Gerry brings a wealth of investigations experience from the DOJ, adding to our bench of experienced former federal prosecutors. Our clients will greatly benefit from his counsel in an increasingly complex period of government enforcement.”
Akin White Collar Defense & Government Investigations Practice co-head Chuck Connolly stated:
“Gerry has handled some of the Fraud Section’s most significant matters, and his experience as a federal prosecutor will be invaluable to our clients amidst an increase in FCPA enforcement at the DOJ and law enforcement agencies around the world.”
Katie Goldstein, co-head of Akin’s White Collar Defense & Government Investigations stated:
“We’re pleased to add an accomplished and respected prosecutor like Gerry to the firm. His knowledge base and skill set will complement our substantial and growing team of former high-level prosecutors and regulators.” With an increase in FCPA enforcement, Moody adds to Akin’s team of former federal prosecutors and regulators advising clients on increased investigations from the DOJ, the SEC and foreign authorities. He also adds to the firm’s unique ability to offer coordinated global capabilities across white collar defense & government investigations, international trade, regulatory and policy practices.”
If indeed there is an “increasingly complex period of government enforcement,” and an “increase in FCPA enforcement at the DOJ,” who plays a role in these issues?
Real human beings of course, including those with supervisory or discretionary authority at the DOJ.
This is why – for approximately 15 years – I have called for restrictions when DOJ/SEC FCPA enforcement attorneys with supervisory and discretionary authority leave the government for private practice careers devoted to the FCPA. (See here, here, here and here among other posts).
The legitimacy and credibility of the DOJ and SEC’s entire FCPA enforcement programs hinge on this policy proposal being adopted.
Like other DOJ or SEC FCPA enforcement attorneys in private practice, Moody’s new Akin bio appears to measure his success at the DOJ – in part – by the number of FCPA enforcement actions brought and the settlement amounts collected.
