Timothy J. Treanor

Tim focuses his practice on a number of enforcement areas, including anti-money laundering, anti-corruption, economic sanctions, export controls, securities enforcement, market manipulation, corporate fraud, antitrust enforcement, asset forfeiture and recovery, monitorships, and trial defense.

Representations of Corporate Clients

AML and Economic Sanctions

• Representing members of the board of directors of a major international payments company before the DOJ in a BSA, money laundering, and Food and Drug Act investigation.
• Defended a prominent, global U.S. financial institution before the DOJ in an investigation of potential BSA/AML violations involving offshore bank transactions.
• Advised and represented one of the world’s largest banks in connection with the imposition by the NYDFS of a compliance monitor to address deficient AML and sanctions compliance controls and facilitated controls enhancements that led to an on-time discharge of the monitor.
• Served for a five-year term as lead counsel to the corporate compliance monitor of HSBC Holdings plc and its subsidiaries appointed by the DOJ, the UK Financial Conduct Authority, and the Board of Governors of the Federal Reserve System in connection with HSBC’s US$1.9 billion resolution of money laundering and sanctions violations.
• Served as lead prosecutor of NETELLER PLC, a U.S. publicly traded payment transmitter, and its founders, for some of the most substantial money laundering offenses in history, and negotiated deferred-prosecution and non-prosecution agreements with corporate defendants in the matter, including appointing and managing one of the earliest corporate compliance monitors.

Securities Enforcement and Financial Services

• Conducting an internal investigation for a prominent U.S. public, health services company into allegations of accelerated revenue recognition and accounting fraud.
• Represented prominent investment firms and commodities traders in connection with the DOJ’s investigation and prosecution of manipulative spoofing in precious metals trading. 
• Represented a federal government–sponsored enterprise (GSE) in connection with allegations of manipulative pricing in GSE bond offerings.
• Defended a global bank in foreign currency exchange trading investigations being conducted by numerous enforcement agencies around the world and negotiated a US$40 million consent order with NYDFS.
• Defended a LIBOR panel bank in investigations by the DOJ, the New York Attorney General (NYAG), and numerous other U.S. enforcement agencies into the potential manipulation of LIBOR rates, and represented the bank before other enforcement agencies around the world, with no enforcement action taken.
• Served as lead counsel to an asset management firm in connection with investigations of potential fraud in the setting of foreign currency exchange rates.
• Served as lead counsel to a bank in connection with investigations of a rogue trader conducted by the Federal Reserve Bank of New York (FRBNY) and the Manhattan District Attorney’s Office.
• Was retained during the financial crisis to advise the FRBNY on fraud risk issues and to conduct a fraud risk assessment in connection with the US$250 billion Term Asset-Backed Securities Lending Facility, one of the federal government’s most important and successful economic recovery programs.
• Defended an inter-dealer brokerage firm in investigations by the SDNY, the NYAG, and the SEC into potentially manipulative credit default swaps trading, with no enforcement action taken.

Anti-corruption and FCPA

• Defended soccer confederation CONCACAF in the DOJ’s investigation of corruption in world football, conducted internal investigations of multiple CONCACAF leadership administrations, and (with co-counsel) recovered in restitution over US$200 million for the world’s leading football organizations.
• Led the defense of a U.S. public company in the life sciences industry in a highly publicized FCPA enforcement action arising from allegations of bribery in Brazil, Mexico, and Argentina and negotiated resolutions with the DOJ, SEC, and Brazilian authorities, totaling approximately US$90 million.
• Defended oil field services company PetroTiger in an investigation of FCPA violations in Colombia and obtained from the DOJ a groundbreaking declination of prosecution.
• Representing a U.S. public medical device company before the SEC in an investigation involving alleged bribe payments to customs officials.
• Secured a declination of prosecution from the DOJ and the SEC for a U.S. publicly traded life sciences company in an investigation of business practices in the Middle East.
• Secured a declination of prosecution from the DOJ for an international commodities trading firm, and a favorable settlement in parallel federal civil litigation, in connection with bribery allegations related to the development of an aluminum smelter in Bahrain.
• Represented a Fortune 100 company before the DOJ and the SEC in connection with the assessment and enhancement of the company’s global corporate compliance program, which led to a declination of prosecution.
• Represented a leading pharmaceutical company before the DOJ and the SEC in connection with the post-acquisition due diligence review of an acquired company’s operations in Indonesia, the Philippines, Colombia, and Poland, leading to resolutions with the DOJ and FCPA for conduct in Indonesia, and conducted investigations and compliance reviews in multiple countries, including China, Singapore, and Australia.
• Helped to secure a declination of prosecution for an international oil and gas company in an investigation of potential corruption in connection with oilfield rights in Libya, Angola, and Iraq.

National Security and International Trade

• Negotiated, for a leading U.S. financial institution, the favorable resolution of a civil suit for treble damages brought under the Anti-Terrorism Act arising from the downing of Malaysia Airlines flight MH17 in 2014 by the Russian military in eastern Ukraine.
• Advised a foreign sovereign in connection with allegations of computer hacking, corruption, and fraud in the U.S. and other jurisdictions.  
• Defended a major foreign bank before the DOJ in an investigation of companies and individuals financing the development of weapons of mass destruction by North Korea, with no enforcement action taken.
• Represented a foreign bank before the Manhattan District Attorney’s Office in the investigation of individuals who were indicted for selling missile-related products and technology to entities involved in Iran’s ballistic missile program.

Antitrust Enforcement

• Represented a leading U.S. insurance company before the NYAG in an investigation of no-poach agreements and anti-competitive employment practices, including negotiating an assurance of discontinuance to resolve any potential exposure to liability.
• Defended corporate clients against enforcement actions by the DOJ and the Federal Trade Commission (FTC), including a six-week preliminary injunction hearing against the FTC in the U.S. District Court for the District of Columbia seeking to enjoin a merger of pharmaceutical wholesalers.

Other Matters

• Represented a victim technology company in connection with the prosecution and trial in the SDNY of individuals who defrauded the company and in efforts to recover assets.
• Participated in negotiating a civil resolution under the Controlled Substances Act for a private equity-owned hospital chain that experienced instances of employee drug diversion. 

Representations of Individual Clients

• Defended commodities traders before the DOJ in connection with the investigation of manipulative spoofing trades in the precious metals markets, with no enforcement action taken.
  
• Defended the “Bitcoin King” before the U.S. Attorney’s Office for the SDNY in connection with the prosecution of money laundering offenses involving the Silk Road website. 
• Defended multiple hedge fund executives, and advised hedge funds, in insider trading investigations related to expert consultant networks conducted by the U.S. Attorney’s Office for the SDNY and the SEC, with no enforcement action taken.
• Represented a former senior manager of S.A.C. Capital Advisors, L.P. (S.A.C.) in connection with insider trading investigations of various employees of S.A.C.
• Defended the former controller of Bernard L. Madoff Investment Securities in connection with the investigation and prosecution of individuals associated with Madoff’s Ponzi scheme.
• Represented an executive of a U.S. insurance company in connection with efforts to reverse a criminal conviction in Kuwait. 
• Represented employees/witnesses at the trial of a victim company’s former CEO.  
• Defended an employee of a major investment bank in connection with the investigation of bid-rigging in municipal tax lien auctions conducted by the DOJ’s Antitrust Division, with no enforcement action taken.
• Represented senior partners of prominent lawyer Marc Dreier in connection with the investigation of his well-publicized fraud scheme and the recovery of assets.
• Served for six years as a member of the Criminal Justice Act panel for the SDNY representing indigent defendants as court-appointed counsel.