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. A former federal prosecutor in the Financial Crimes and Special Prosecutions Section of the Chicago U.S. Attorney’s Office, Mr. Boutros is a leading figure in white collar defense. He 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. 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. 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 by Chambers USA in the area of White Collar Crime & Government Investigations in Illinois, Mr. Boutros is 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." Others have described him as a “phenomenal attorney who is quick to identify the key issues and develop an effective course of action." Chambers also 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.” 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.” He is also the Co-Hiring Partner of the firm’s Chicago office.

Mr. Boutros has personally represented clients in matters involving general fraud, embezzlement, the Travel Act, FARA, OFAC, RICO, tax, commercial bribery, kickback schemes, public corruption, Inspector General investigations, insurance fraud, bank fraud, securities and accounting violations, healthcare and FDA violations, environmental crimes, trade secret theft, cyber hacking and extortion incidents, 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. In addition, Mr. Boutros was retained as an FCPA expert to render a formal legal opinion in a transnational post-acquisition dispute.

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 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; convicted one of the country’s “Top 10 Most Wanted” mortgage fraud defendants; convicted Edgewater Medical Center’s owner and operator for crimes relating to more than US$188 million in judgments; 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 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.

A deeply active member of the legal community, Mr. Boutros has been a lecturer in law at the University of Chicago Law School since 2011, where he teaches a course on corporate criminal prosecutions and investigations. Among his leadership and board activities, he 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. 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 has also formally adopted many of the Task Force’s recommendations in its recently-promulgated regulations on the subject.

Mr. Boutros has authored nearly 100 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 more than 75 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.

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 2015, he was also elected into the American Law Institute and today serves on ALI’s Regional Advisory Group for Region 7 (Illinois, Michigan, and Wisconsin). 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 matters as a white collar practitioner

The Audit Committee of a public company in an SEC investigation and internal investigation.
A large multinational corporation in a cross-border FCPA investigation out of Canada and China.
Another large multinational corporation and several of its subsidiaries in multiple matters being investigated and prosecuted out of the USAO and the DOJ, including coordination with nearly a dozen international law firms.
One of the world’s largest telecommunications companies in litigation and a multi-week civil trial involving theft of trade secrets, RICO, conspiracy, among other claims.
A public company in a cross-border internal investigation into potential books and records and internal controls violations.
A high technology company and several executives in a criminal investigation conducted by the USAO, the FDA and the DEA following a raid of its corporate offices. The case was resolved with a US$3 million misdemeanor NPA and no criminal charges against the individuals.
A CEO in a criminal antitrust investigation, including through the DOJ Antitrust Division’s Leniency Program.
A corporation and its principals in a criminal antitrust prosecution conducted by the DOJ Antitrust Division and FBI.
A software company in a public corruption investigation being conducted by the USAO and FBI.
A government contractor in a public corruption investigation being conducted by the USAO, FBI and Inspector General.
A government contractor in a Department of Defense Inspector General whistleblower investigation.
A CEO and Founder, as well as an information technology company, in a criminal tax investigation being conducted by the USAO for the Southern District of New York and the IRS.
A former controller of a publicly traded company in SEC and Special Litigation Committee investigations relating to revenue recognition issues and earnings restatement.
A public company in an internal investigation into a senior executive’s eight-figure theft and embezzlement scheme, as well as follow-on federal criminal prosecution of a former senior executive.
A chemical manufacturing company charged with environmental crimes involving the packing, labelling and transportation of hazardous materials. The case resulted in prosecutors dropping all 10 criminal counts and resolution through a modest civil settlement.
An American multinational banking and financial services corporation and its senior executive in a federal criminal trial involving more than US$100 million in victim bank losses.
A multi-billion dollar company in an international investigation into allegations of kickbacks, bid rigging and breach of fiduciary duties.
Corporate victims before the USAOs in criminal theft of trade secrets cases.
A 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 the DOJ declining to bring criminal charges and SEC resolving the case on favorable terms.
A Fortune 200 company against criminal allegations of price manipulation in the natural gas market relating to the California energy crisis. Negotiated US$50 million DPA with the DOJ and the USAO for the Northern District of California.
A major insurer in a US$90 million arbitration of cross-border loans and political risk insurance. The case was resolved with a favorable settlement for the client.

Featured matters as a federal prosecutor

Convicted the owner and operator of a 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 the 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 the world’s largest online drug trafficker on Silk Road, described then by the government in court filings as the most sophisticated and extensive criminal marketplace of its kind on the Internet.
Designated as the government’s nationwide point of contact for a Top International Criminal Organization Target (TICOT) and led the government’s money laundering investigation into one of the largest global digital currency exchangers and its top executive.
Investigated and prosecuted the largest criminal customs fraud, food fraud, and international trade fraud cases in U.S. history, the first in 2010 at nearly US$80 million, and the second series in 2013 at nearly US$180 million, for a total of approximately US$260 million.

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

Dechert’s Trade Secret Litigation practice was ranked Band 2 in World Intellectual Property Review’s inaugural “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)
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