Partner

Kristin Graham Koehler

White Collar Defense and Investigations
Crisis Management and Strategic Response
Healthcare

kkoehler@sidley.com

Washington, D.C. +1 202 736 8359

- Letter
- A4

KRISTIN GRAHAM KOEHLER is a member of the firm’s Management Committee and Executive Committee. She also serves as the managing partner of the Washington, D.C. office and head of the D.C. Litigation group. Kristin previously served as a global co-leader of the firm’s White Collar Defense and Investigations practice. She is consistently recognized as a leading white collar lawyer.

Kristin has handled numerous United States Department of Justice (DOJ) criminal investigations involving healthcare fraud, procurement fraud, public corruption, antitrust, securities fraud and violations of the Foreign Corrupt Practices Act (FCPA). She also has significant experience representing clients in DOJ civil qui tam investigations, state attorney general investigations and congressional investigations, and she has negotiated numerous Corporate Integrity Agreements with the HHS Office of Inspector General (OIG). Kristin routinely conducts sensitive internal investigations on behalf of corporations and individuals. She also regularly counsels clients on the creation, enhancement, implementation and assessment of compliance programs. Kristin has participated in jury trials in a number of federal district courts and appeals in a number of appellate courts, including the U.S. Supreme Court.

Kristin’s work representing clients has earned her acknowledgment in numerous industry publications, including Chambers Global, Chambers USA, Benchmark Litigation, Washingtonian magazine, LMG Life Sciences, and Best Lawyers.

Kristin was recognized by Chambers Global for Foreign Corrupt Practices Act (USA) (2022–2025). She also has been recognized by Chambers USA for Foreign Corrupt Practices Act (USA – Nationwide) (2021–2024).
Kristin was recognized by Chambers USA for False Claims Act (USA – Nationwide) (2023–2024).
Kristin was recognized by Chambers USA for Litigation: White-Collar Crime & Government Investigations (District of Columbia) (2013–2024).
Chambers USA 2021 highlights Kristin’s “substantial expertise in handling a variety of investigations and criminal proceedings, particularly those involving alleged healthcare fraud and FCPA violations.” Chambers praises Kristin as “very knowledgeable on substantive law,” and “very well respected by the DOJ.”
Chambers USA 2021 DC White-Collar Crime & Government Investigations Guide includes the following client comments: Kristin “really gets to the heart of the issue, and then manages the entire caseload so you don’t need to worry.” “She is the right person to have in a tempest; she is unflappable, and truly delivers.”
Chambers USA 2021 Nationwide FCPA Guide highlights Kristin for her significant FCPA experience in major cross-border corporate investigations, as well as individual representations, and includes the following client comments: Kristin “is phenomenal; not only is she extremely knowledgeable but she is also very responsive and easy to work with, and she understands our business.” “She is able to think on her feet and doesn’t get rattled in high-risk situations.” “She is very precise, focused and pragmatic.”
According to Global Investigations Review (2021), Kristin “is described by her peers as a force to be reckoned having risen through the ranks and emerged as a distinguished lawyer in the white-collar space.”
Kristin was recognized as a “Life Sciences Star” by LMG Life Sciences for her work in White-Collar/Government Investigations (2019–2024).
Kristin has been named one of the “Top 250 Women in Litigation” (2017–2025), a “Litigation Star” in Washington, D.C. (2015–2018, 2020–2025), and a “National Practice Area Star” (2021–2025) in White Collar Crime by Benchmark Litigation.
Washingtonian magazine included Kristin in its roster of “Washington, D.C.’s Best Lawyers” for Criminal Defense — White Collar (2015–2019). The Corporate Crime Reporter also recognized Kristin as one of the “Top 150 Women in White Collar Crime” (2016).

Prior to joining Sidley, Kristin served as a law clerk to the Honorable David G. Larimer, Chief Judge of the U.S. District Court for the Western District of New York. She graduated with honors from the University at Buffalo, State University of New York, where she was the assistant executive editor of the Law Review and a member of the National Trial Advocacy Team. While at the University at Buffalo, Kristin was the recipient of the Justice Phillip Halpern Award for Excellence in Writing on the Law Review and the Law Faculty Award for Outstanding Contributions to the Law School.

Experience

A sampling of Kristin’s representative client matters includes:

Healthcare Fraud

Represented Ista Pharmaceuticals, Inc. in criminal and civil qui tam investigations involving off-label promotion and kickbacks brought by DOJ’s Consumer Protection Branch and Civil Fraud Section and the U.S. Attorney’s Office for the Western District of New York.

Procurement Fraud

Represented the world’s largest aluminum extrusion manufacturing company, Hydro Extrusion LLC, in DOJ criminal procurement fraud and civil qui tam investigations involving alleged non-conforming parts supplied for NASA and Department of Defense programs, as well as in administrative suspension and debarment proceedings before NASA.

Public Corruption

Represented the former CFO of a publicly traded Silicon Valley company regarding public corruption allegations concerning a Fourth of July trip to Las Vegas with a government official.

Antitrust

Represented a Fortune 100 transportation company in connection with grand jury investigations of price fixing in the air cargo and freight forwarder industries.
Represented a major electronics company in connection with several DOJ grand jury investigations of anti-competitive conduct in the cathode ray tube, plasma display panels and optical digital device markets.
Represented a Japanese executive in connection with grand jury investigation of price fixing in the auto parts industry in which the executive was successfully carved-in to the company’s resolution.

Securities Fraud

Represented a former American International Group (AIG) executive in United States v. Ferguson, et al., a criminal securities fraud case in the District of Connecticut regarding an allegedly fraudulent reinsurance transaction by AIG, in which a favorable deferred prosecution agreement was secured.

FCPA

Successfully obtained prosecutorial declinations from DOJ and SEC for companies in significant FCPA investigations. Most recent declinations were for a multinational pharmaceutical company involving allegations of FCPA violations in Tunisia and for a multinational transportation company involving allegations of FCPA violations in Iran.

Civil Qui Tams

Represented biopharmaceutical company Incyte Corporation in a civil qui tam action, United States of America ex rel. Dillon v. Incyte Corporation, involving its charitable donations to patient assistance foundations. After an intensive DOJ investigation, the government declined to intervene in the qui tam action. The matter was resolved very favorably for the company without any admission of liability or a Corporate Integrity Agreement.
Represented Laureate Education, Inc., one of the world’s largest higher education institutions, in connection with a qui tam action, United States of America ex rel. Sawyer and Kosicek v. Walden University LLC and Laureate Education, Inc. After an extensive internal investigation and considerable engagement with the DOJ, successfully convinced DOJ to decline to intervene in the qui tam action, and the relators subsequently dismissed the case.
Represented Bayer Corporation in a qui tam action, United States of America ex rel. Simpson v. Bayer Corporation, et al., involving U.S. Department of Defense contracts and Bayer’s cholesterol-lowering drug Baycol. After an extensive investigation by DOJ, successfully convinced DOJ to decline to intervene in the matter.

State AG Investigations

Represented a major national food distribution corporation in investigations by the Attorney General Offices of New York, Florida and California involving alleged claims that the company failed to pass back discounts and rebates to the states in connection with contracts with state entities.
Represented major pharmaceutical manufacturers in state attorneys’ general multi-state investigations regarding fraudulent marketing practices involving prescription drugs, over-the-counter drugs and dietary supplements.

Congressional Investigations

Represented a major defense contractor in connection with a GAO audit and congressional investigation concerning the U.S. Navy’s Littoral Combat Ship (LCS) Program.
Represented a major defense contractor in a Senate Armed Services Committee investigation and hearing into the use of private subcontractors in Iraq and Afghanistan.

Corporate Integrity Agreements

Represented GlaxoSmithKline and numerous other manufacturers in Corporate Integrity Agreement negotiations with HHS OIG.
Has also been successful on a number of occasions in convincing OIG that a CIA was not warranted.

Internal Investigations

Conducted an internal investigation for the Human Rights Campaign and the Human Rights Campaign Foundation related to the inclusion of the president of the two organizations, Alphonso David, in the New York Attorney General’s report of the investigation of then-Governor Andrew Cuomo.
Represented The Ohio State University football coach Urban Meyer relating to the allegations regarding an assistant coach on his staff.
Conducted internal investigations of both a Fortune 25 and a Fortune 100 company regarding allegations of impropriety on the part their CEOs.
Conducted internal investigations into “Me Too” claims against senior officers of several major companies.

Trials

Member of the trial team in United States v. Tyson Foods, Inc., representing the company in jury trial on a 36-count indictment charging conspiracy to violate federal immigration laws and seeking criminal forfeiture of over US$100 million, which resulted in jury acquittal on all counts.
Member of the trial team in Pickett v. IBP, representing the nation’s largest beef-packing company in a jury trial of class action claims seeking over US$2 billion in damages on the theory that supply contracts had anticompetitive effect on beef cattle prices. The trial court’s order of judgment as a matter of law was affirmed by the Eleventh Circuit.
Lead lawyer in rare original action in the U.S. Supreme Court, Alabama, et al. v. North Carolina, No. 132, in which Sidley represented Alabama, Florida, Tennessee and Virginia against North Carolina for the latter’s failure to site a low-level radioactive waste facility pursuant to an interstate compact.

Kristin holds several leadership positions within Sidley. She is a member of the firm’s Management Committee, Executive Committee, and Office of General Counsel. She also serves as the managing partner of the Washington, D.C. office and head of the D.C. Litigation group.
Kristin is the global secretary and D.C. chapter co-leader of the Women’s White Collar Defense Association and is the co-chair of the Chief Compliance Officers’ Forum.
Kristin is a member of the American Law Institute (ALI), where she contributes to ALI’s work of clarifying the law through Restatements, Principles, and Model Codes.
An active member of the American Bar Association (ABA), Kristin is a former chair of the Young Lawyers Subcommittee of the ABA’s Criminal Justice Section, White Collar Crime Committee. She also has held several leadership positions in the ABA’s Section of Litigation, serving as the National Chair of the Section’s Annual Conference (2008), and is a former chair of its Criminal Litigation Committee.

Credentials

Admissions & Certifications

U.S. Supreme Court
U.S. Court of Federal Claims
U.S. District Court, District of Columbia
U.S. District Court, W.D. of New York
District of Columbia
New York

Education

University at Buffalo Law School, The State University of New York, J.D., 1994 (cum laude)
State University of New York - Geneseo, B.A., 1991 (magna cum laude)

Clerkships

David G. Larimer, U.S. District Court, W.D. of New York (1996 - 1999)