Andrew S. Boutros

Partner Chicago Washington, D.C.

Andrew S. Boutros, the Regional Chair of the U.S. White Collar practice, is resident in the firm’s Chicago and Washington, D.C. offices. He is a former federal prosecutor in the Financial Crimes and Special Prosecutions Section of the Chicago U.S. Attorney’s Office. Mr. Boutros now represents companies large and small, public and private, victims and targets as well as their boards, audit committees, officers, directors and other individuals in government enforcement matters (DOJ, USAO, FBI, SEC and other agencies) and internal investigations. His practice also includes trials, false claims litigation, crisis management response, strategic counseling and compliance-related work. In this regard, Mr. Boutros served as Legal Counsel to the Independent Compliance Monitor for a series of pharmacy entities, pursuant to a U.S. Department of Labor administrative agreement. Also, twice Mr. Boutros was hired to serve as a legal expert on the FCPA. In the first engagement, he was retained as an FCPA expert to render a formal legal opinion in a transnational post-acquisition dispute. Most recently, he was hired by one of the world’s largest public companies to serve as a testifying legal expert on the FCPA in criminal proceedings in the Middle East. Mr. Boutros has been a member of the American Law Institute since 2015 and today serves on ALI’s Regional Advisory Group for Region 7 (Illinois, Michigan, and Wisconsin). Most recently, he was inducted into the International Academy of Financial Crime Litigators, which has a membership that stands at only 79 worldwide from 31 jurisdictions, with just 18 Fellows in the United States. He has been teaching law at the University of Chicago Law School since 2011.

Client and Market Feedback: Identified by The Legal 500 as a "key lawyer" in Dechert’s White Collar practice, Mr. Boutros is described as "exceptional, the real deal - very thorough, meticulous and client-focused." Ranked repeatedly by Chambers USA in the area of White Collar Crime & Government Investigations in Illinois, Mr. Boutros is also described as a "phenomenal attorney who is quick to identify the key issues and develop an effective course of action." He is "incredibly smart and analytical," "incredibly knowledgeable, strategic and passionate towards his clients," "tireless and fearless," and is "very effective in advocating for his clients." Others have commented on his "encyclopedic knowledge of the law in the white-collar area." He is also described as a "very diligent, creative and tenacious lawyer . . . he is a thought-leader and tactician who thinks quickly and deeply along multiple tracks at the same time. A brilliant lawyer." Chambers further notes that he is "terrific to work with" and a person who "excels at everything he does and has the Midas touch - he is super smart, creative and hard-working." "He thinks outside of the box and is a problem solver. He is extremely quick and efficient." Also, nominated by top legal decision makers at large organizations with US$700 million or more in revenue, Mr. Boutros has been selected as a 2022 and 2021 BTI Client Service All-Star for delivering "absolutely superior client service." Clients describe Mr. Boutros as a "standout partner," who is "very good at communicating and keeping us informed" and "is fantastic at guiding us through a matter."

Representative Areas of Practice: Mr. Boutros has personally represented clients in matters involving general fraud, embezzlement, trade secret theft, cryptocurrencies, cyber breaches and extortion incidents, OFAC, RICO, FARA, the Travel Act, tax violations, commercial bribery, kickback schemes, public corruption, Inspector General investigations, insurance fraud, bank fraud, securities and accounting violations, healthcare and FDA violations, environmental crimes, criminal antitrust violations, supply chain issues, government contract disputes involving allegations of wrongdoing, whistleblower allegations and the False Claims Act, among others. Mr. Boutros also has significant experience handling criminal customs, trade and antidumping duty fraud cases. Since the early 2000s, he has conducted FCPA investigations in Canada, China, Russia, Europe and the Middle East and advised clients on FCPA corporate compliance matters and programs.

Government, Trial, and Appellate Experience: Over the course of his career, Mr. Boutros has led a number of high-profile cases of national and international significance, which the Chicago Sun-Times described in a profile of Mr. Boutros as "some of the toughest, most sophisticated cases at the Dirksen Federal Courthouse." As a federal prosecutor, he coordinated efforts with international law enforcement authorities in more than 20 countries and charged and prosecuted crimes involving US$500 million in losses, proceeds and judgments. In this regard, Mr. Boutros (i) convicted the world’s largest online drug trafficker on the dark website, "Silk Road," and was a member of the government’s inter-agency, multi- district Silk Road Task Force; (ii) convicted one of the country's "Top 10 Most Wanted" mortgage fraud defendants; (iii) convicted Edgewater Medical Center’s owner and operator for crimes relating to more than US$188 million in judgments; (iv) successfully prosecuted the most extensive international criminal trade, customs and antidumping fraud cases of their kind, which Bloomberg Businessweek described as "the largest food fraud in U.S. history;" and (v) negotiated two of the Northern District of Illinois’s earliest criminal corporate deferred prosecution agreements. While in the U.S. Attorney’s Office, Mr. Boutros also handled hundreds of matters; briefed and argued appeals to the Seventh Circuit Court of Appeals; and tried or prepped for trial dozens of cases.

Teaching and Professional Activities: A deeply active member of the legal community, Mr. Boutros has been a lecturer in law at the University of Chicago Law School for every year since 2011, where he teaches a course on corporate criminal prosecutions and investigations. Among his leadership and board activities, Mr. Boutros is a Co-Founder and National Co-Chair of the American Bar Association’s Criminal Justice Section Global Anti-Corruption Committee, a board member of the International Association of Independent Corporate Monitors and a member of the Chicago Crime Commission. Also, for six years, he was a voting member of the ABA’s Criminal Justice Section Council, the governing body of the Section with its more than 16,000 members. Before that, he was a Special Advisor to the Council. In addition, Mr. Boutros was Founder and National Chair of the ABA Criminal Justice Section’s Task Force on College Due Process Rights and Victim Protections. The Task Force’s bipartisan Report and Recommendations were both unanimously approved by the Task Force’s members and unanimously endorsed by the Criminal Justice Section Council. That work has since become among the key foundational documents that colleges and universities from across the country, including the university system for the State of California, have turned to for guidance for handling allegations of student sexual misconduct. The Department of Education also formally adopted many of the Task Force’s recommendations when it promulgated regulations on the subject.

Articles, Books, and Speaking Engagements: Mr. Boutros has authored nearly 150 articles, thought pieces and book chapters. He has also published two books: the first on compliance, The ABA Compliance Officer’s Deskbook (2017) and the second with Oxford University Press on global anti-corruption, From ‘Baksheesh’ to Bribery: Examining the Global Fight Against Corruption and Graft (2019). Mr. Boutros has chaired and organized various legal programs and been a presenter at 85 domestic and international programs. His presentations have covered the FCPA, international corruption, white collar criminal defense, government enforcement, customs and antidumping duty fraud, international and trade fraud, food fraud, supply chain integrity, corporate social responsibility, human trafficking and other related topics. As part of his thought leadership, Mr. Boutros coined the term “carbon copy” prosecution, a phrase that describes a growing global enforcement trend that has since been recognized by the Department of Justice in its “pile on” enforcement policy.

Honors and Recognitions: Mr. Boutros’s successes have earned him recognition from the government, law enforcement and legal communities. In 2015, the Federal Law Enforcement Officers Association selected Mr. Boutros as the national prosecutor of the year, presenting him with the prestigious National Prosecutorial Award. In 2014, the American Bar Association awarded Mr. Boutros the Criminal Justice Section’s Norm Maleng Minister of Justice Award, among the highest honors the ABA can confer upon a prosecutor. The FBI, the U.S. Department of Homeland Security and U.S. Customs and Border Protection have also presented Mr. Boutros with some of their highest honors. In addition, senior government officials have showcased his cases in their testimony before Congress, including hearings before the U.S. Senate and U.S. House of Representatives. In 2018, Mr. Boutros and his work were featured in the debut of Netflix’s Emmy-nominated documentary series on food fraud, Rotten, in the episode, "Lawyers, Guns, and Honey." Mr. Boutros is a frequent legal commentator on national and international television.

Featured corporate representations

Audit Committee of public company in multi-billion-dollar SEC investigation and internal investigation.
Audit Committee of public company in FCPA investigations in China and Russia.
Large multinational corporation in cross-border FCPA investigation out of Canada and China.
One of world's largest multinational telecommunications company and several of its subsidiaries against criminal charges of racketeering, trade secret theft, and other alleged offenses in pending federal criminal case in New York.
One of world's multinational telecommunications company and one of its subsidiaries in civil litigation and multi-week trial in Texas involving theft of trade secrets, RICO, conspiracy, among other claims.
Multiple companies in cryptocurrency ecosystem in disputes with SEC and state regulators, including whether certain cryptocurrencies are securities.
Public company in cross-border internal investigation into potential books and records and internal controls violations.
High technology company and several executives in criminal investigation conducted by USAO, FDA and DEA following raid of its corporate offices; case was resolved with US$3 million misdemeanor NPA and no criminal charges against individuals.
Chemical manufacturing company criminally charged with environmental crimes involving packing, labelling and transportation of hazardous materials; case resulted in prosecutors dropping all 10 criminal counts and agreeing to modest civil settlement.
Software company in public corruption investigation conducted by USAO and FBI.
Government contractor in public corruption investigation conducted by USAO, FBI and Inspector General.
Government contractor in Department of Defense Inspector General whistleblower investigation involving activities in Afghanistan.
Public company in internal investigation into senior executive’s eight-figure theft and embezzlement scheme, as well as follow-on federal criminal prosecution of former senior executive.
American multinational banking and financial services corporation and its senior executive in federal criminal trial involving more than US$100 million in victim bank losses.
Multi-billion-dollar company in international investigation into allegations of kickbacks, bid rigging and breach of fiduciary duties.
Various corporate victims before USAOs in criminal theft of trade secrets cases.
Fortune 10 company and several of its subsidiaries in criminal and administrative FCPA investigations relating to alleged kickbacks paid to the Iraqi government during the U.N.-sponsored Oil-for-Food Program; defense culminated in DOJ declining to bring criminal charges and SEC resolving case on favorable terms.
Fortune 200 company against criminal allegations of price manipulation in natural gas market relating to California energy crisis; negotiated US$50 million DPA with DOJ and USAO for Northern District of California.
Major insurer in US$90 million arbitration of cross-border loans and political risk insurance; case was resolved with favorable settlement for client.

Featured representations of executives and other individuals

Lead cooperator in federal criminal prosecution related to COVID-19 test fraud, resulting in guilty verdict against biotech company's President on all counts, largely due to client's key trial testimony.
CEO in global criminal antitrust investigation, including through DOJ Antitrust Division’s Leniency Program; obtained amnesty for CEO.
Corporation and all its principals in criminal antitrust prosecution conducted by DOJ Antitrust Division and FBI; obtained declinations for two principals, sentences of probation for other three executives, and corporate criminal fine that represented 86% discount off low-end of advisory Sentencing Guidelines range.
Chief Technology Officer of publicly traded company in DOJ, FBI, and EPA criminal and administrative investigations.
CFO and several employees of public life sciences company in Audit Committee investigation.
CEO and Founder, as well as information technology company, in criminal tax investigation conducted by USAO for Southern District of New York and IRS.
Former controller of publicly traded company in SEC and Special Litigation Committee investigations relating to revenue recognition issues and earnings restatement.

Featured matters as federal prosecutor

Convicted owner and operator of defunct Chicago hospital, Edgewater Medical Center, in one of the district’s first-ever Sarbanes-Oxley conspiracy cases, with complex offshore trusts and monetary judgments totaling more than US$188 million.
Convicted one of nation’s “Top 10 Most Wanted” mortgage fraud defendants as part of a long-term undercover fraud investigation.
Member of Silk Road Task Force; convicted world’s largest online drug trafficker on Silk Road, described then by government in court filings as most sophisticated and extensive criminal marketplace of its kind on Internet.
Designated as government’s nationwide point of contact for Top International Criminal Organization Target (TICOT) and led government’s money laundering investigation into one of largest global digital currency exchangers and its top executive.
Investigated and prosecuted largest criminal customs fraud, food fraud, and international trade fraud cases in U.S. history - first in 2010 at nearly US$80 million, and second series in 2013 at nearly US$180 million, for total of approximately US$260 million.

**Includes matters handled at Dechert or prior to joining the firm.**

Chambers USA, White Collar Crime & Government Investigations in Illinois (ranked for five years)
The Legal 500 (multiple)
BTI Client Service All-Star (2022 and 2021)
Recognized in WIPR Insights 2023 Global Trade Secrets Rankings

The 2022 Monaco Memorandum: Changes to DOJ Corporate Enforcement Policy, CPI Antitrust Chronicle (February 2023)
“More Cooperation Please”: DOJ Revises Enforcement Policy to Encourage Even Greater Cooperation, The Corporate Governance Advisor, Volume 31, No. 2 (March/April 2023)
U.S. Supreme Court to Decide When Attorney-Client Communications That Contain “Hybrid” Legal and Business Advice Are Protected by the Attorney-Client Privilege, Pratt’s Privacy & Cybersecurity Law Report, Volume 9, Number 2 (February/March 2023)
U.S. Justice Department Announces Substantial Revisions to Corporate Enforcement Policy – The Journal of Federal Agency Action – Volume 1, Number 1 (January-February 2023)
Compensation Clawback Crackdowns – An Emerging Enforcement Focus, FCPA Professor, November 7, 2022
Betraying the Bench: Could the SCOTUS Leaker Face Criminal Charges?, The ABA Criminal Justice Section Newsletter, Volume 31, No. 1: Fall 2022
Practice Tip: Beware Individual Criminal Liability for CEOs and CCOs as DOJ Begins Requiring Compliance Certifications, The ABA CJS White Collar Crime Committee Newsletter, Summer-Fall 2022

Speaking engagements since 2016

“NPAs and DPAs: 10 Years Since Massey,” The University of Chicago Law Review, “Briefly” a podcast production (Co-Presenter; December 2020)
“The New US Administration and What It Will Mean for Investigations Specialists,” GIR Live Interactive: Regional Spotlight - North America (Panelist; December 2020)
“Corporate Criminal Liability Brown Bag,” ABA CJS Practice-Ready Clinic,” Online (Presenter; December 2020)
“Corporate America Must Stand Up Against Modern-Day Slavery,” Corporate Lab, Univ. of Chicago Law School, Chicago, IL (Guest Lecturer; October 2020)
“Internal Investigations,” Corporate Lab, Univ. of Chicago Law School, Chicago, IL (Guest Lecturer; October 2020)
“How Corporate America Can Help Defeat Modern-Day Slavery,” Room 800, Chicago Club (Presenter; September 2020)
“Monitoring the Effectiveness of Financial Controls,” Dechert Coffee Break Compliance Broadcast Series (Presenter; August 2020)
“Compliance Drill: Re-Thinking Contingency Planning and Compliance Amid More Overlapping, Unpredictable Exposure: ABC, Fraud, AML, Trade, Sanctions and Geopolitics,” ACI’s 36th International Conference on the Foreign Corrupt Practices Act, Washington, D.C. (Moderator; December 2019)
"Internal Investigations," Corporate Lab, Univ. of Chicago Law School, Chicago, IL (Guest Lecturer; November 2019)
"The Risks of Importing ‘Tainted’ Merchandise: Weathering the Growing Nexus Between Trade Violations and Anti-Corruption Risks for Companies and Individuals," ACI Forum on Anti-Corruption Compliance in High Risk Markets, Washington, D.C. (Moderator & Panelist; July 2019)
"Criminal Trade Secret Theft: What You Need to Know," Webinar (November 14, 2018)
"Changing Landscape of Internal Investigations," Corporate Lab, University of Chicago Law School, Chicago, IL (Guest Lecturer; October 2018)
"Abuse Lawsuits & Liabilities: New Factors to Consider," Permanent Capital 4th Annual Investment Committee Symposium, New York, NY (Featured Speaker; October 2018)
"Overview of Selected Trial Issues," Child Exploitation and Human Trafficking, University of Chicago Law School, Chicago, IL (Guest Lecturer; Winter 2018)
"Life, Law, and Leisure: Navigating Lawyer Wellness," Corporate Lab, Univ. of Chicago Law School, Chicago, IL (Facilitator and Co-Presenter; February 2018)
"Honeygate: Trade & Customs Fraud Enforcement and White-Collar Crime," United States Department of Commerce 5th Annual ITA Day, Washington, D.C. (Keynote Speaker; January 2018)
"Internal Investigations," Corporate Lab, Univ. of Chicago Law School, Chicago, IL (Guest Lecturer; January 2018)
"Lawyers, Guns and Honey," Episode One of Documentary Series, Rotten, Netflix (Featured; January 2018)
"Conducting Effective Internal Investigations: Practical and Strategic Considerations," Illinois Council of School Attorneys, Webinar (Presenter; September 2017)
"Money Laundering Red Flags in Real Estate," Partner Retreat Meeting, San Diego, CA (Presenter; September 2017)
"Trade & Customs Fraud Enforcement: A 'High Priority,'" First 100 & Beyond Strategy & Planning Summit for Businesses, Chicago, IL (Panelist; May 2017)
"President Trump and the FCPA: How to Navigate the FCPA in the New Administration," ABA CJS Nationwide Roundtable Series, Chicago, IL (Moderator; February 2017)
"College Sexual Assault: Protecting the Rights and Interests of the Victim and the Accused," ABA Ninth Annual Fall Institute, Washington, D.C. (Moderator; November 2016)
"Protecting Your Most Valuable Assets – Trade Secrets, IP, and Your Employees," Trade Secrets Breakfast Briefing, Chicago, IL (Presenter; November 2016)
"Tipper X and Insider Trading," Corporate Lab, Univ. of Chicago Law School, Chicago, IL (Facilitator & Introductory Remarks; October 2016)
"Intersection of Trade Secrets Violations and the Criminal Law," Webinar (Panelist; October 2016)
"The Role of Corruption in Human Trafficking & the Foreign Corrupt Practices Act," Human Trafficking Seminar, Loyola Univ. School of Law, Chicago, IL (Presenter; October 2016)
"Human Trafficking (Modern Slavery) in Supply Chains: Risks and Realities," Partner Retreat Meeting, Scottsdale, AZ (Presenter; September 2016)
"Sexual Assault on College Campuses: Balancing the Rights and Interests of the Accused and the Victim," ABA Presidential Showcase Program, San Francisco, CA (Moderator; August 2016)
"The Modus Operandi of Corruption: Detecting Bribery Schemes, High Risk Structures, Hidden Parties and other Questionable Transactions," ACI 7th Global Forum on Anti-Corruption Compliance in High Risk Markets, Washington, D.C. (Panelist; July 2016)
"Food Fraud Prevention Overview and Strategies," 2016 Food Safety Summit, Rosemont, IL (Panelist; May 2016)
"The Prosecutors of Silk Road and its Off-Shoot: Lessons Learned and Thoughts for the Future," Univ. of Chicago Law School Conference on Data Privacy and Cybersecurity, Chicago, IL (Moderator & Panelist; April 2016)
"All-Participant Roundtable," Univ. of Chicago Law School Conference on Data Privacy and Cybersecurity, Chicago, IL (Moderator; April 2016)
"Transnational Investigations and Enforcement Efforts," Child Exploitation and Human Trafficking, University of Chicago Law School, Chicago, IL (Guest Lecturer; Winter 2016)
"Catch Me if You Can: International Trade Fraud on the Rise," University of Virginia School of Law Student Legal Forum, Charlottesville, VA (Featured Speaker; February 2016)
"Human Rights in Business: A Movement Toward Corporate Consciousness," Northwestern Conference on Human Rights, Chicago, IL (Moderator; January 2016)

American Law Institute, Member & Member of Regional Advisory Group for Region 7 (Illinois, Michigan, and Wisconsin)
International Academy of Financial Crime Litigators, Fellow
American Bar Foundation, Life Fellow
Litigation Counsel of America, Fellow
ABA Criminal Justice Section Council, past Voting Member
ABA Criminal Justice Section Global Anti-Corruption Committee, Co-Founder & National Co-Chair
ABA Criminal Justice Section Victims of Crime Task Force & Subgroup Committee Chair on Third Parties
ABA International Law Section, Corporate Social Responsibility Committee, Senior Advisor
ABA Criminal Justice Section CLE Board Membership, Board Member
ABA Criminal Justice Section Task Force on College Due Process Rights and Victim Protections, past National Chair
Bloomberg BNA Criminal Law Reporter and White Collar Crime Report, Advisory Board Member
Chicago Crime Commission
Federal Law Enforcement Officers Association – Chicago Chapter, Associate Member and past Chief Business Officer & Board Member
International Association of Independent Corporate Monitors, Board Member
Mitchell A. Mars Foundation, Board Member
Various ABA Criminal Justice Section and University of Chicago Law School programs, institutes and symposiums; past Chair and Member

United States Court of Appeals for the Sixth Circuit, Honorable Eugene E. Siler, Jr.

Offices

Chicago

35 West Wacker Drive, Suite 3400, Chicago, IL, United States of America 60601-1608

+1 312 646 5803
+1 312 646 5858

Washington, D.C.

1900 K Street, NW, Washington, DC, United States of America 20006-1110

+1 202 261 3300
+1 202 261 3333

Services

White Collar, Compliance and Investigations

Trials

Litigation

Anti-Corruption Compliance and Investigations

Securities Litigation/Enforcement

Whistleblower Claims and False Claims Act Cases

Litigation, Compliance and Regulatory Enforcement

Crisis Management

Education

Virginia Tech, B.S., In-Honors, summa cum laude
University of Virginia School of Law, J.D.

Admission

Illinois
District of Columbia
Maryland