Alex is a member of the Government Investigations and White Collar Litigation department, and co-head of McGuireWoods’ Strategic Risk and Compliance team. His practice focuses primarily on advising and supporting corporate and individual clients in the areas of white collar criminal defense and internal investigations.
He has a particular focus on financial industry investigations, anticorruption laws such as the U.S. Foreign Corrupt Practices Act (FCPA), export control laws and sanctions and trade restrictions, including those administered by the Office of Foreign Assets Control (OFAC), in addition to general white collar defense and corporate compliance matters. His client work has taken him to 21 countries on six continents.
Alex has participated in numerous internal investigations for large corporate clients, and in the defense of criminal and regulatory investigations involving alleged violations of export control laws, healthcare fraud, mortgage fraud, securities fraud, financial fraud, environmental crimes and bribery. He also has experience in related civil litigation, including the defense of False Claims Act/qui tam litigation from initial DOJ investigations through resolution, and the defense of claims arising under Title III of the Helms Burton Act.
Alex has played a key role in the design, implementation and conduct of multiple ethics and compliance risk assessments, gap analyses, audits and other reviews focusing on various subjects, including anticorruption compliance, export controls, trade restrictions and anti-money laundering. He has extensive experience helping major corporate clients design and implement ethics and compliance programs and key components thereof. He has conducted compliance audits, reviews and risk assessments for several Fortune 500 clients in a variety of industries across various subjects, including FCPA audits, investigations, training, and M&A and third-party due diligence. Alex also counsels numerous clients regarding compliance with cannabis-related laws and regulations. He regularly advises clients in these areas on an ongoing basis.
Alex’s experience includes working as a member of an independent monitor team. He has been involved in the successful pursuit of civil claims arising from an FCPA plea agreement and settlement.
Alex is active in his community civic organizations, serving as President of the Virginia Chapter of the Juvenile Diabetes Research Foundation (JDRF). While earning his law degree at the University of Richmond, he was a member of the McNeil Law Honor Society. As an undergraduate at the University of Virginia, he received the Rachel St. Paul Poetry Prize.
Experience
- Assisting clients in the assessment and defense of claims threatened under Titles III and IV of the Helms Burton Act.
- Representation of a Fortune 500 defense contractor in a $2.5 billion qui tam lawsuit filed by a former employee over alleged manufacturing process and product quality defects.
- Representation of a Fortune 500 financial institution in a three-year grand jury investigation conducted by the U.S. Attorney’s Office for the Western District of Virginia and SIGTARP alleging misadministration of the Home Affordable Modification Program (HAMP), which resulted in a non-criminal resolution via a first-of-its-kind restitution and remediation agreement valued at up to $320 million.
- Representation of a financial institution in its development of its cannabis banking compliance program.
- Representation of a major food distribution company in a multi-jurisdictional price gouging investigation associated with pandemic pricing controls.
- Investigation of potential FCPA violations by several non-U.S. operating subsidiaries of a Fortune 10 company, resulting in voluntary disclosure to the DOJ and SEC (with no adverse action taken), several follow-on investigations of operations in Central and South America, and ongoing involvement in related reviews across the company’s operations worldwide.
- Conducting a global anticorruption review of one of the world’s leading multinational medical device manufacturers in connection with its acquisition by a Fortune 500 pharmaceutical and medical device company in a multibillion-dollar transaction.
- Assisting a Fortune 500 mixed industrial client in overseeing a due diligence program covering more than 300 third-party agents, distributors and other company representatives across multiple lines of business operating in dozens of countries.
- Ongoing representation of a Fortune 500 energy company on export control, anticorruption, trade restrictions and other compliance matters, including revising policies, procedures, contractual provisions and screening tools with regard to trade restrictions, export controls and FCPA/anticorruption concerns.
- Representation of a privately-held international commodity trading company in a grand jury investigation involving the EPA and the U.S. Attorney’s Office for the Southern District of Texas regarding alleged environmental violations in connection with the export of certain petroleum products from the United States, and subsequent disposal of related materials outside the United States.
- Representation of an international Fortune 500 food manufacturer in a joint investigation by the EPA, the Ohio Attorney General’s Office and state and local environmental regulators of whistleblower allegations at the Ohio processing facility of a company subsidiary.
- Representation of an international Fortune 500 mixed industrial manufacturer in a joint investigation by the U.S. Attorney’s Offices for the Western District of Virginia and the District of Massachusetts and alleged false statements related to a defense-related government contract.
- Representation of a doctor and his company in one of the largest Medicare fraud cases brought in Virginia as of that date, which was prosecuted by the U.S. Attorney’s Office for the Eastern District of Virginia.
- Anti-Bribery & Anti-Corruption (FCPA)
- Bank Defense and Counseling
- Bank Secrecy Act and Anti-Money Laundering Counseling and Defense
- Cannabis, Hemp & CBD
- Digital Health, Technology and Innovation
- Energy Enforcement
- Environmental, Social & Governance (ESG)
- Government Investigations & White Collar Litigation
- Immigration
- International Competition & Trade
- State Attorneys General
- Strategic Risk & Crisis Management
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University of Richmond School of LawJD
summa cum laude, Manuscripts Editor, Law Review
2004 -
University of VirginiaBA
with Distinction
1999
Member, Virginia State Bar
Member, Virginia Bar Association
President, Virginia Chapter, Juvenile Diabetes Research Foundation
- Speaker, "Anatomy of a Whistleblower: How Compliance Program Failure Creates False Claims Act Risk," Compliance in the Real World — A Practical Roundup of Today’s Top Issues, October 25, 2017
- Speaker, "When Compliance Programs Fail: Truth and Consequences," Compliance in the Real World: A Practical Discussion About Today’s Top Issues, McGuireWoods LLP Conference, May 17, 2017
- Speaker, "Recapping and Forecasting Anticorruption Enforcement Trends," SEC Compliance and Disclosure Update, McGuireWoods LLP SEC Practice Complimentary Webinar Series, March 7, 2017
- Speaker, "Data Breach Prevention and Response: An Interactive Simulation," The Data Privacy and Security Puzzle: Do You Have All the Pieces?, November 3, 2016
- Speaker, Do Criminal Prosecutions Make Food Safer? The Problem With Regulating Food Safety Through Criminalization, Washington Legal Foundation Web Seminar Series, October 12, 2016
- Speaker, Food Safety Crisis & Risk Management, McGuireWoods LLP Webinar, March 3, 2016
- Speaker, "Foreign Corrupt Practices Act," 7th Annual Medical Device and Life Sciences Conference, November 19, 2015
- Panelist, Strategic Risk & Compliance Trends for Private Equity, McGuireWoods LLP Webinar, November 10, 2015
- Speaker, "Foreign Corrupt Practices Act," 6th Annual Medical Device and Life Sciences Conference, November 18, 2014
- Speaker, "Compliance and Investigations: Prevention and Response," Healthcare Litigation Conference, McGuireWoods LLP, August 14, 2014
- Speaker, "Compliance and Investigations: Prevention and Response to Claims," Healthcare Litigation Conference, McGuireWoods LLP, May 29, 2014
- Faculty, "Third-Party Due Diligence & Evolving Paradigms in Supply Chain Due Diligence - Beyond Anticorruption Regulations," TRACE International Anti-Bribery Specialist Accreditation Program (TASA), October 24, 2012
- Speaker, SEC Compliance and Enforcement Update, McGuireWoods LLP SEC Practice Complimentary Webinar Series, October 23, 2012
- Panelist, "Whistleblowers, State Secrets and National Security," Montpelier Center for the Constitution, April 1, 2012
- Speaker, SEC Reporting & Enforcement Update, November 11, 2009
- Panelist, "Accessing Business Opportunities in the Naval and Coastguard Programmes of the United States," UK Society of Maritime Industries and British Naval Equipment Association, November 9, 2009
- Virginia
- U.S. Court of Appeals for the 2nd Circuit
- U.S. Court of Appeals for the 4th Circuit
- U.S. District Court for the Eastern District of Virginia
Selected for inclusion in Who’s Who Legal, Investigations: Lawyers, 2019, 2020, 2021, 2022
Lexology Client Choice Award for White Collar Crime, Virginia, 2017
Named to “Legal Elite,” Criminal Law, Virginia Business, 2015
- Author, G7+ Coalition Issues Alert on Russian Oil Price Cap Evasion Methods and How to Report Violations, Subject to Inquiry, February 23, 2024
- Author, Disruptive Technology Strike Force Continues Focus on Trade Secret Theft, Export Control Enforcement, McGuireWoods Legal Alert, February 15, 2024
- Author, BIS Continues Enforcement Policy Ramp-Up, Subject to Inquiry, February 2, 2024
- Author, Recent Sanctions Enforcement Actions Demonstrate Importance of Incorporating All Available Data into Screening, Subject to Inquiry, January 31, 2024
- Co-author, Impacts of Sanctions and Export Controls on Supply Chains, Global Investigations Review, The Guide to Sanctions: Fourth Edition, September 29, 2023
- Author, California Climate Accountability Package Poised to Disrupt, Subject to Inquiry, October 3, 2023
- Author, "Strike Force Actions Underscore Foreign Risks For Tech Cos.," Law360, August 10, 2023
- Author, Departments of Justice, Commerce and Treasury Issue Tri-Seal Compliance Note on Voluntary Self-Disclosure of Potential Violations, Subject to Inquiry, July 31, 2023
- Author, Disruptive Technology Strike Force Initiates Federal Prosecutions Targeting Trade Secret Theft, McGuireWoods Legal Alert, June 27, 2023
- Author, U.S. DOJ and Partners Increasing Enforcement of Sanctions and Export Controls, Subject to Inquiry, March 6, 2023
- Author, FinCEN Alert Highlights Potential U.S. Real Estate Investments by Sanctioned Russian Elites, Consumer FinSights, January 30, 2023
- Author, Consumer Watchdog Calls on California AG to Investigate Rising Energy Prices, McGuireWoods Legal Alert, January 23, 2023
- Author, Commerce Department Releases Preliminary Findings on Chinese Solar Manufacturers’ Alleged Circumvention, McGuireWoods Legal Alert, December 5, 2022
- Author, Brazilian Airline to Pay Millions in Coordinated Foreign Bribery Resolution, Subject to Inquiry, September 21, 2022
- Author, Remote Form I-9 Inspection of Employee Documents Likely to Become Permanent Option, Subject to Inquiry, August 25, 2022
- Co-author, "Impacts of Sanctions and Export Controls on Supply Chains," Global Investigations Review, The Guide to Sanctions: Third Edition, June 2022
- Author, Less Is More? DOJ Signals Shift to More Targeted Evidence Collection, Subject to Inquiry, June 27, 2022
- Author, DOJ, SEC Announce Foreign Corrupt Practices Act Settlement With Waste Management Company, Subject to Inquiry, April 25, 2022
- Author, New Revelations in Ukraine Lead to Tightening Global Sanctions, Subject to Inquiry, April 8, 2022
- Author, Western Companies Starting to Feel Impact of Russian Sanctions, Subject to Inquiry, March 24, 2022
- Author, FinCEN Encourages “Increased Vigilance,” Highlights Red Flags for Evasion of Russian Sanctions, Subject to Inquiry, March 16, 2022
- Author, Biden Administration Amends “Buy American” Rules to Increase Domestic Content Requirements, McGuireWoods Legal Alert, March 10, 2022
- Author, DOJ Launches “Task Force KleptoCapture” in Response to Russian Invasion, Subject to Inquiry, March 9, 2022
- Author, U.S. and Allies Significantly Expand Sanctions and Related Restrictions on Russia and Belarus, Subject to Inquiry, February 28, 2022
- Author, Additional Sanctions on Russia and the Importance of Business Contingency Planning, Subject to Inquiry, February 23, 2022
- Author, Biden Administration Issues Initial Ukraine Sanctions, Subject to Inquiry, February 22, 2022
- Author, What Significant Russian Sanctions Could Look Like and How to Prepare, Subject to Inquiry, January 18, 2022
- Author, Perils of Global Expansion: Ad Agency Fined $19 Million for FCPA Violations, Insufficient Controls, Subject to Inquiry, October 25, 2021
- Author, Sanctions and Export Compliance Strategies for Supply Chains, Subject to Inquiry, August 12, 2021
- Contributor, "Part III: Sanctions in Practice – Impacts of Sanctions and Export Controls on Supply Chains," Global Investigations Review's The Guide to Sanctions: Second Edition, July 13, 2021
- Author, Biden Administration Orders Comprehensive Review of U.S. Supply Chain, McGuireWoods Legal Alert, March 1, 2021
- Author, Price Gouging Enforcement in the Wake of COVID-19: Where Is the FTC?, Subject to Inquiry, May 27, 2020
- Author, The Tip of the Iceberg Emerges: Initial Wave of Class Actions Reflect How Private Causes of Action Will Add Significantly to Price Gouging Litigation, Subject to Inquiry, May 14, 2020
- Author, Price Gouging Investigations Are Coming: What Industry Needs to Understand, Subject to Inquiry, May 7, 2020
- Author, What the Venezuela Sanctions May Mean for Future Sanctions Programs, Subject to Inquiry, March 11, 2019
- Author, 2nd Circuit Clarifies Limits of FCPA’s Extraterritorial Reach, Subject to Inquiry, September 7, 2018
- Author, Series of DOJ Enforcement Policy Announcements Provides Promising Guidance, Subject to Inquiry, May 25, 2018
- Co-author, "DOJ Enforcement Policy Announcements Provide Promising Guidance," The FCPA Blog, May 23, 2018
- Author, "FCPA Enforcement Is Here To Stay: SEC May However Soften When True Criminal Intent Is Lacking," Metropolitan Corporate Counsel, July 2017
- Co-author, The Past, Present, and Uncertain Potential of Corporate Monitors, Washington Legal Foundation, July 2017
- Co-author, "Regulatory Enforcement Post-Election," Today's General Counsel, February/March 2017
- Author, Congress Votes to Disapprove SEC’s Resource Extraction Disclosure Rule, Subject to Inquiry, February 7, 2017
- Author, Big Changes Come With The New Form I-9 Published by USCIS, Subject to Inquiry, November 15, 2016
- Author, Data Breach Prevention and Response: Top 10 Takeaways From Our Interactive Simulation, McGuireWoods Legal Alert, November 14, 2016
- Co-author, "Brackett and Neale: Enforcement Innovations for the Post-Yates Environment," The FCPA Blog, October 31, 2016
- Author, Identifying Enforcement Innovations to Prepare for the Post-Yates Enforcement Environment, Subject to Inquiry, October 31, 2016
- Co-author, "A Compliance Plan for the Extractive Industries Payment Disclosure Rule," The FCPA Blog, September 28, 2016
- Co-author, A Compliance Plan for the Extractive Industries Payment Disclosure Rule, Subject to Inquiry, September 28, 2016
- Co-author, "Practice Note: How to prepare for the SEC’s Resource Extraction Disclosure Rule," The FCPA Blog, September 26, 2016
- Author, Increased Fines on the Horizon for Immigration Law Violations, Subject to Inquiry, July 7, 2016
- Author, The Export/Immigration Dilemma: Don’t Let OSC Catch Your HR Department Unaware, McGuireWoods Legal Alert, May 5, 2016
- Co-author, "FDA Flexes Its Muscles in Food Fights," Metropolitan Corporate Counsel, March 30, 2016
- Author, 5 Key Takeaways from McGuireWoods’ Latest Food Safety Crisis & Risk Management Webinar, McGuireWoods Legal Alert, March 8, 2016
- Author, The Olympus Debacle: Why Internal Whistleblowing is a Good Thing for Compliance, Subject to Inquiry, March 7, 2016
- Co-author, "The Increasing Risk Of Criminal Prosecution For Food Cos.," Law360, January 22, 2016
- Author, Iran Sanctions and the Implementation of the JCPOA: Lots of Changes, but Little Impact on U.S. Businesses?, McGuireWoods Legal Alert, January 20, 2016
- Author, Addressing Adulterated Food Risk, McGuireWoods Legal Alert, January 19, 2016
- Co-author, "Anticorruption Enforcement in Brazil: Part 2," Business Crimes Bulletin, December 2015
- Author, 6 Key Takeaways from McGuireWoods’ Latest Strategic Risk & Compliance Webinar, McGuireWoods Legal Alert, November 23, 2015
- Author, A New FCPA Policy May Be Coming, but Questions Remain, McGuireWoods Legal Alert, November 13, 2015
- Author, "Overreacting to risk can ruin a compliance program," The FCPA Blog, November 3, 2015
- Co-author, "Anticorruption Enforcement in Brazil: Part 1," Business Crimes Bulletin, November 2015
- Author, SEC ‘Broken Windows’ Enforcement Policy Is Showing FCPA Results, Subject to Inquiry, October 7, 2015
- Author, "SEC ‘broken windows’ enforcement policy is showing FCPA results," The FCPA Blog, October 6, 2015
- Author, "SEC and FinCEN delivering One-Two Punch to Private Equity," FCPA Blog, September 9, 2015
- Author, SEC and FinCEN Delivering One-Two Punch to Private Equity, Subject to Inquiry, September 9, 2015
- Co-author, "Compliance Concerns Complicate Credit Agreements," Just Anti-Corruption, September 4, 2015
- Author, Anti-Corruption Enforcement in Brazil is in High Gear, Subject to Inquiry, September 2, 2015
- Co-author, "China’s Focus On Commercial Bribery Is A Wake-Up Call," Law360, July 28, 2015
- Author, China’s Focus on Combatting Commercial Bribery Is a Wake-Up Call, Subject to Inquiry, July 21, 2015
- Author, Still Certain about Uncertainty − Waiting on the Details in the New Iran Nuclear Deal, McGuireWoods Legal Alert, July 15, 2015
- Co-author, "The FCPA Implications of China’s Plan to Consolidate State-Owned Enterprises," Law360, March 31, 2015
- Co-author, "The FCPA Implications of China’s Plan to Consolidate State-Owned Enterprises," Main Justice, March 25, 2015
- Author, The FCPA Implications of China’s Plan to Consolidate State-Owned Enterprises, Subject to Inquiry, March 24, 2015
- Author, Revisiting the Conflicts Minerals Rule, McGuireWoods Legal Alert, March 4, 2015
- Author, Guilty Plea in DOJ’s First Criminal Prosecution for Campaign Finance Coordination, Subject to Inquiry, February 23, 2015
- Co-author, "Revisiting the Conflict Minerals Rule," Global Trade and Customs Journal, February 2015
- Author, With Record-Setting False Claims Act Recoveries, What Will DOJ Do for an Encore?, Subject to Inquiry, December 3, 2014
- Co-author, "Update on Brazil: Embraer SA and Anti-Corruption Progress," Main Justice, November 13, 2014
- Co-author, Update on Brazil: Embraer SA and Anti-Corruption Progress, Subject to Inquiry, November 7, 2014
- Author, U.S. Department of Treasury Adopts New Sanctions Against Russia, McGuireWoods Legal Alert, May 1, 2014
- Author, SEC Confirms Conflict Minerals Rule Remains (Largely) in Place, McGuireWoods Legal Alert, April 30, 2014
- Author, EU, U.S. Slap Sanctions on Russian and Ukrainian Officials, McGuireWoods Legal Alert, March 18, 2014
- Co-author, "A Tale Of 2 Coasts: Handling Whistleblower Investigations," Law360, February 26, 2014
- Co-author, "Brazil’s Clean Companies Act Comes into Effect," Main Justice, February 10, 2014
- Author, Brazil’s Clean Companies Act Comes into Effect, Subject to Inquiry, February 6, 2014
- Author, A Tale of Two Coasts: Handling Whistleblower Investigations, Subject to Inquiry, January 28, 2014
- Co-author, SEC comments bring commercial bribery clearly into FCPA scope, The FCPA Blog, January 6, 2014
- Co-author, SEC Comments Bring Commercial Bribery Clearly into FCPA Scope, Subject to Inquiry, December 20, 2013
- Author, DPAs, NPAs and the Hybrid Corporate Monitor, Subject to Inquiry, December 17, 2013
- Author, Brazil is the Latest Country to Change the Anticorruption Landscape, Subject to Inquiry, August 27, 2013
- Author, Documentation Critical to Dodd-Frank Compliance Under Proposed Supervisory Guidance, Subject to Inquiry, August 14, 2013
- Author, Extractive Industry Continues to be a Focus of Anticorruption Enforcement, Subject to Inquiry, April 19, 2013
- Author, Despite Public Perception, Financial Institutions Have Not Received Favored Treatment, Subject to Inquiry, March 26, 2013
- Author, SEC Adopts Final Rule on Conflict Minerals Disclosure Requirements, McGuireWoods Legal Alert, August 24, 2012
- Author, "Foreign Bribery and Illegal Exports, What the Scientific Community Should Know," Public Interest Report, June 6, 2011
- Co-author, "Foreign Bribery and Illegal Exports: What the Scientific Community Should Know," Public Interest Report, Federation of American Scientists, Spring 2011
- Author, 60-Day Suspension: Form I-129 (Petition for a Nonimmigrant Worker) Export Certification, McGuireWoods Legal Alert, December 23, 2010
- Author, H-1B and L-1 Employers Must Certify Compliance with U.S. Export Control Laws, McGuireWoods Legal Alert, December 22, 2010
- Co-author, Taking Your Medicine, Washington Legal Foundation, November 2010
- Author, DOJ’s FCPA Team Pressing Forward with Pharma Probes, McGuireWoods Legal Alert, July 20, 2010
- Author, New UK Bribery Bill: Impact on French organisations doing business with the UK, McGuireWoods Legal Alert, March 2, 2010
- Author, Enhanced Anticorruption Enforcement in the UK, McGuireWoods Legal Alert, March 2, 2010