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Whether Buyer or Seller: Heed This WARNing

Certain New York Retailers Must Now Establish Workplace Violence Prevention Programs

Serving as the Co-Leader of BakerHostetler’s cross-disciplinary Compliance practice team, Patrick focuses on assessing enterprise-wide and business line and regulatory-specific corporate client risks in various industries and providing advice on ethics and compliance governance structures, policies, procedures and internal controls tailored to the client’s risk profile. Patrick also advises on anti-corruption due diligence for complex domestic and cross-border acquisitions. Patrick is the former Chair of the New York City Bar Association’s Compliance Committee (now serving on the City Bar’s Board of Directors and Board Audit Committee) and regularly speaks and writes on “best practices” ethics and compliance matters.

Patrick also has experience representing clients in complex commercial and bankruptcy litigation, most notably serving as a litigation team leader in the Bernard L. Madoff Investment Securities LLC liquidation – one of the largest financial frauds in U.S. history. Patrick approaches matters calmly, analytically and with a view toward developing fact-based strategies that most resonate with regulators, judges and juries.

Patrick is also involved in the development of associates at BakerHostetler, and he is an active member of the New York office’s Mentorship Program. Over the past several years, Patrick has served on the office’s Mentorship Committee and formally and informally mentored many of the New York office’s associates, created and delivered national associate training programs and serves as one of the assignment coordinators for the New York office’s summer associates.

core/freeform

J.D., New York Law School, 2007, 

B.B.A., The City University of New York, Baruch College, 2004, 

<ul>
<li>New York Metro Super Lawyers &#8220;Rising Star&#8221; (2012 to 2022)</li>
<li>Recipient of the Judge Joseph F. Solomon Award for Excellent Character and Fitness</li>
<li>Recipient of the NYSBA Committee on Legal Education and Admission to the Bar 2007 Law Student Legal Ethics Award</li>
</ul>

New York

Jonathan New, Patrick Campbell, Rachel Ofori Author Article for Law.com’s Business Crimes Bulletin

DOJ’s Criminal Division Announces New Pilot Program on Voluntary Self-Disclosure for Individuals

The Lines Are Open! DOJ Adds New Tool in Anticorruption Efforts With Whistleblower Pilot Program

Patrick Campbell, Jonathan Barr, Carlos Ortiz Author Article on New Anti-Extortion Law

DOJ to Corporations – “Knock on Our Door Before We Knock on Yours”

Foreign Extortion Prevention Act: DOJ’s New Tool to Prosecute Global Corruption and What Companies Need to Know (and Do) Right Now

Congress Expands DOJ’s Power to Prosecute Corruption with the Foreign Extortion Prevention Act

Treasury Revisits Past Rulemaking to Bring Investment Advisers Under AML Oversight

BakerHostetler Attorneys Author Article on New Safe Harbor Policy in Business Crimes Bulletin

Culture, Cooperation and CCO Liability: SEC Enforcement Director Gurbir Grewal Gives Keynote Address at New York City Bar Association’s Annual Compliance Institute

Corporate compliance poses significant challenges; NYC Bar institute offers crucial guidance

DOJ Announces Department-Wide Safe Harbor Policy for Voluntary Self-Disclosures Made in the Context of Mergers and Acquisitions

SEC Chief Accountant Warns About Need for Comprehensive Risk Assessments

Get the details: SEC risk alert tells broker-dealers to improve anti-money laundering efforts

Warning: SEC Exams and Enforcement Targeting Broker-Dealer AML Compliance

SEC and CFTC Show No Signs of Slowing Down Enforcement Actions for Financial Firms’ Use of Off-Channel Communications

White Collar, Litigation and Privacy Attorneys Advise Companies to Assess Governance Practices Amid Government Crackdown

​​​​​​​Protecting Your Business: Challenges Presented by Recent DOJ and SEC Enforcement and Compliance Initiatives

Patrick Campbell Elected to NYCBA Board of Directors

New DOJ Policies Tie Employee Compensation to Compliance

Federal Prosecutors to Assess Procedures Around Use of Personal Devices and Messaging Applications When Evaluating Corporate Compliance Programs 

DOJ Announces Major Corporate Enforcement Policies

Jonno Forman, Patrick Campbell and Krista Fuller Author Article on SEC Consent Order

SEC Finds Investment Adviser CEO Liable for Failing to Supervise High-Risk Representative

DOJ Corporate Compliance Certifications Appear to Be Here to Stay

FinCEN Requires Wide Array of Companies To Report Beneficial Ownership Information To Strengthen Transparency of US Financial System

Patrick Campbell Says Companies Must Plan to Handle Misconduct Complaints

Patrick Campbell Co-Chairs NYC Bar’s Compliance Institute 2022

Deputy AG Lisa Monaco Announces Tough-on-Corporate-Crime Updates to DOJ Policies

Patrick Campbell, Jonathan New and Francesca Rogo Author Business Crimes Bulletin Article About Federal Scrutiny of Companies’ Anti-Money Laundering Compliance

Webinar: The Balancing Act: How to Protect Privilege While Seeking Cooperation Credit in a Government Investigation

Attorney General Merrick Garland Emphasizes Criminal Corporate Enforcement and Individual Accountability

George Stamboulidis, Pat Campbell, Christina Gotsis, Lauren Lyster Discuss Future of PPP Fraud Enforcement

DOJ Criminal Division Head Kenneth Polite Cautions Compliance Crackdown

Jonathan New, Patrick Campbell and Francesca Rogo Article Discusses Protection of Privileged Information

Patrick Campbell Discusses Defense of Corporate Compliance Programs

SEC Begins Reversal of Trump Era Changes to Whistleblower Program

Jonathan New, Patrick Campbell, Lauren Lyster Author Article Examining the Federal Government’s Expanding Whistleblower Programs

Patrick Campbell Oversees Release of Framework for Chief Compliance Officer Liability in the Financial Sector

Webinar: Assessing Your Compliance Program with Data and Analytics: How Can You Meet the DOJ’s Expectation of Using Operational Data and Analytics In Your Compliance Programs?

Jonathan New, Patrick Campbell, Victoria Stork Author Article that Reviews Biden Administration’s Cross-Border Enforcement Priorities

George Stamboulidis, Patrick Campbell, Christina Gotsis Author Article Examining Expanded Paycheck Protection Program

Webinar: Paycheck Protection Program 2.0: What Borrowers Need to Know

Important Lessons from the DOJ’s First Civil Action for CARES Act Loan Fraud

The Anti-Money Laundering Act of 2020: What Companies Need to Know

Patrick Campbell Comments on Potential for Clearer Liability Criteria for Compliance Officers

George Stamboulidis, Patrick Campbell, Lauren Lyster Author Article Examining Regulatory Risks for CARES Act Borrowers

SEC Commissioner Peirce Delivers a Speech on Defining the Parameters of CCO Liability

150 BakerHostetler Attorneys Named 2016 Super Lawyers; 91 Named Rising Stars

Bloomberg’s article “Madoff Victims to Get $322 Million in Trustee Payout” acknowledges BakerHostetler attorneys at announcement of fifth distribution plans

The Associated Press reports on BakerHostetler and the Madoff Recovery Initiative recoveries of $10.5 billion

CNBC reports on BakerHostetler and the Madoff Recovery Initiative in article Madoff Recoveries Top $10 Billion With New Settlement, “… an amount virtually no one thought possible”

Patrick T. Campbell and Kathryn M. Zunno Co-Chair CLE Event for Federal Bar Council in Atlantic City; David J. Sheehan to Present

BakerHostetler talks with USA Today about the SIPA Trustee’s fourth pro rata interim distribution; states Madoff Recovery Initiative nears $6 billion in distributions to allowed claimants

BakerHostetler’s settlement with JPMorgan Chase and the ongoing Madoff Recovery Initiative Discussed on National Public Radio’s All Things Considered

BakerHostetler appears on NPR’s All Things Considered to discuss Madoff Recovery Initiative; host Robert Siegel interviews SIPA Trustee Irving Picard and his Chief Counsel David Sheehan

Madoff Recovery Initiative surpasses $5 billion in distributions to allowed claimants; CNBC’s Scott Cohn discusses latest recovery with BakerHostetler’s SIPA Trustee Irving Picard and his Chief Counsel David Sheehan

Madoff Recovery Initiative Marks Fourth Anniversary … Moves into Fifth Year Still Building Recovery Momentum

BakerHostetler’s work recovering more than half of the losses in the Madoff Ponzi scheme featured on WNYC in interview on The Brian Lehrer Show

Press Release: Second Interim Distribution of Recovered Funds to Madoff Claim Holders

Press Release: United States Supreme Court Denies Certiorari, Upholding Net Equity Decision in BLMIS Liquidation

The Wall Street Journal showcases BakerHostetler and the “unprecedented magnitude” of the global recovery efforts in article “The Madoff Liquidation, Three Years Later”

Press Release: Initial Interim Distribution of Recovered Funds to Madoff Claims Holders

The New York Times reports on BakerHostetler’s negotiation and settlement with the Picower Estate for $5 billion in the SIPA liquidation of Bernard L. Madoff Investment Securities LLC

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Ethics, Compliance and Due Diligence Advice
<ul>
<li>Directed an enterprise-wide risk assessment for a global construction company, which included (i) industry benchmarking to catalog potential enterprise risk categories, (ii) identifying particular enterprise risks through employee interviews and internal and external data analysis, (iii) evaluating and prioritizing identified risks, and (iv) designing risk monitoring and mitigation strategies for management and Board adoption.</li>
<li>Benchmarked and enhanced global fintech company’s compliance program regarding (i) compliance governance structure, reporting, monitoring and training, (ii) Code of Conduct and compliance policies and procedures on, among other areas, anti-corruption and third-party diligence, conflicts of interest, anti-money laundering, and whistleblowing and internal investigations, and (iii) enterprise risk management.</li>
<li>Advised multi-national consulting firm on ethics and compliance matters, including on anti-corruption and anti-money laundering compliance, in connection with establishing operations in the U.S.</li>
<li>Conducted anti-corruption risk assessments, revised anti-corruption policies and procedures, and provided anti-corruption training for organizations.</li>
<li>Advised companies in different industries on policies and procedures for responding to government search warrants (sometimes referred to as “dawn raids”) and subpoenas and provided training on same.</li>
<li>Counsels various international companies on “best practices” ethics and compliance governance and other matters, and on anti-corruption due diligence for acquisition targets.</li>
<li>Advises companies on crafting anti-money laundering programs compliant with the Bank Secrecy Act and its implementing regulations.</li>
<li>Conducted transactional due diligence for a U.S. bankruptcy trustee concerning a large payment made to an international creditor.</li>
<li>Conducted Foreign Corrupt Practices Act (FCPA) risk assessment for clients considering business venture in country with high corruption risk.</li>
<li>Conducted anti-corruption due diligence for an international provider of food, beverage and retail services for airports and motorways in connection with the potential acquisition of food and beverage outlet service contracts for airports in India.</li>
<li>Conducted anti-corruption due diligence on manufacturing and business support services acquisition targets.</li>
</ul>
Government Investigations, Enforcement Proceedings and Monitorships
<ul>
<li>Represents numerous foreign claimants in one of the largest civil asset forfeiture actions brought by the U.S. Department of Justice’s (DOJ) Kleptocracy Asset Recovery Initiative involving alleged corruption and embezzlement by a former Nigerian president and his family and associates.</li>
<li>Represented company that provides health care sharing programs in administrative proceeding brought by the New York State Department of Financial Services (DFS) concerning alleged violations of the New York financial services and insurance laws.</li>
<li>Represented four former executives of an Internet services company in a civil action brought by the U.S. Federal Trade Commission in the Southern District of Florida alleging that the individuals, and more than 40 corporate entities, violated Section 5 of the Federal Trade Commission Act by operating websites that were allegedly deceptive and misleading to consumers.</li>
<li>Represented insurance broker in DFS examination.</li>
<li>Routinely represent clients across industries in responding to grand jury and civil investigatory subpoenas.</li>
<li>Represented a major data company under investigation by the DOJ’s Consumer Protection Branch for allegations of mail fraud.</li>
<li>Served as a key lawyer in the complex representation of a former London-based JPMorgan Chase managing director, nicknamed “the London Whale” by the media, in investigations conducted by the DOJ, the U.S. Securities and Exchange Commission (SEC) and the U.S. Commodity Futures Trading Commission (CFTC), related to a multibillion dollar trading loss for the bank. Developed an understanding of complicated credit derivative instruments in order to effectively represent the client. Through the mastery of complex facts, the application of government investigations experience and a multidisciplinary approach, the team developed a strategy to navigate the client through parallel U.S. and U.K. investigations. The team secured a rare non-prosecution agreement with the DOJ and agreements with the SEC and the CFTC, including one of the first non-prosecution agreements executed by the CFTC for an individual.</li>
<li>Assisted the former ethical practices attorney for Local 14-14B of the International Union of Operating Engineers by managing a team that oversaw the enforcement of a Consent Decree. Activities included anticorruption investigations, commencement of disciplinary proceedings against corrupt union members and oversight of the union&#8217;s policies and procedures to ensure fair job referrals and elections.</li>
<li>Represented an individual in a SEC investigation involving an alleged global securities fraud scheme, resulting in no charges.</li>
<li>Represented an individual in connection with a high-profile public corruption investigation conducted by the DOJ, resulting in no charges.</li>
<li>Represented employees of an orthopedics company in a DOJ investigation into the alleged provision of illegal kickbacks to orthopedic surgeons, resulting in no charges.</li>
<li>Represented a worldwide pharmaceutical distribution company in connection with a nationwide U.S. Drug Enforcement Administration investigation into the distribution of controlled substances under the Controlled Substances Act.</li>
</ul>
Commercial and Bankruptcy Litigation
<ul>
<li>Since 2009, has worked on a variety of litigation matters in connection with BakerHostetler&#8217;s role as court-appointed counsel to the Securities Investor Protection Act (SIPA) trustee, Irving H. Picard, for the Madoff liquidation. Is a key member of the Picard v. Madoff et al. legal team, which is responsible for the SIPA trustee&#8217;s avoidance litigation seeking to recover assets for the Fund of Customer Property for ultimate distribution to the defrauded customers of Madoff&#8217;s Ponzi scheme. Litigates other multimillion-dollar avoidance and recovery actions against foreign and domestic defendants to recover fraudulent transfers received from BLMIS.</li>
<li>Represented nonprofit organization against defamation claims brought in New York state court.</li>
<li>Represented a real estate management company in litigation brought by a disgruntled commercial tenant who sued the client and attempted to place blame on the client for his business failure, alleging the client had failed to maintain the property. Navigated rules and procedures related to state court litigation, handled document discovery and depositions, and ultimately settled the matter on the eve of trial on terms favorable to the client.</li>
</ul>

Patrick T. Campbell

Patrick T. Campbell

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