Charles (Chuck) Duross heads the firm’s global anti-corruption practice and is a partner in the Securities Litigation, Enforcement and White-Collar Defense Practice Group. With more than a dozen years of experience principally focused on white-collar cases, Mr. Duross’s practice has an emphasis on white-collar criminal matters, including internal corporate investigations, compliance counseling, due diligence regarding third parties and business transactions, and defense of clients before government enforcement agencies. Indeed, Mr. Duross has overseen FCPA investigations relating to business in more than 50 countries. In addition, as a veteran trial attorney, Mr. Duross has a proven track record in the courtroom in high-profile, high-stakes trials.
Selected Significant Representations
- Leading an FCPA internal investigation for a major multinational company with operations in more than 100 countries worldwide
- Led FCPA/anti-corruption investigations for various major multinational companies involving conduct in Africa, Asia, and Latin America
- Representing a senior bank executive who is the subject of an FCPA internal investigation
- Conducted pre-investment and pre-acquisition enhanced FCPA/anti-corruption due diligence in numerous multi-billion dollar deals in Africa, Asia, and Latin America
- Assisting numerous companies, from start-ups to Fortune 50 corporations, with drafting codes of conduct and compliance procedures, conducting risk assessments, gap analysis and compliance benchmarking, and enhancing compliance programs
- Go-to outside FCPA and anti-corruption legal and compliance counsel to leading Global 500 multinational corporations across industries and regions
Mr. Duross most recently served as a Deputy Chief in the Fraud Section in the Criminal Division of the U.S. Department of Justice, where he led the Foreign Corrupt Practices Act (FCPA) Unit and was in charge of all of the DOJ’s FCPA investigations, prosecutions and resolutions in the United States. Internationally recognized for his leading role in developing and implementing the government’s FCPA enforcement strategy, he was widely credited with developing the current enforcement regime and recruiting and leading a talented team of prosecutors who have brought some of the most important FCPA cases in the statute’s 36-year history. Under his leadership, the FCPA Unit resolved more than 40 corporate cases, which included two-thirds of the top 25 biggest corporate resolutions ever, resulting in approximately $1.9 billion in monetary penalties, and secured convictions of more than two dozen business executives and money launderers. As the head of the FCPA Unit, Mr. Duross oversaw countless voluntary disclosures, decided which matters would be declined, administered DOJ’s FCPA Opinion Release Procedure and was responsible for interviewing, selecting and reviewing the work of 17 independent corporate monitors.
In investigating and prosecuting transnational bribery cases, Mr. Duross worked with every major U.S. Attorney’s Office and law enforcement agency in the United States, law enforcement counterparts around the world and numerous multi-lateral development banks, including the World Bank. For example, Mr. Duross worked with the Australian Federal Police, Royal Canadian Mounted Police, the Tribunal de Grande Instance de Paris, Indonesia’s Anti-Corruption Commission (KPK), the Tokyo Public Prosecutor’s Office, Mexico’s Procuraduría General de la República, Norway’s Økokrim, the Swiss Attorney General’s Office, Thailand’s National Anti-Corruption Commission, the City of London Police, Crown Prosecution Service, Metropolitan Police and the Serious Fraud Office. Mr. Duross also led training sessions of foreign prosecutors and investigators both in the United States and abroad.
While in the Fraud Section, Mr. Duross led the development of a deferred prosecution agreement (DPA) template for FCPA cases, which formed the basis for a DPA template later adopted for use by the entire Criminal Division, and he also led the effort to update and restructure the enhanced compliance components of DPAs in FCPA cases. As a recognized expert, Mr. Duross was consulted by UK officials who were considering whether to pursue legislation permitting deferred prosecution agreements in the United Kingdom.
Mr. Duross’s tenure was also marked by his efforts to make FCPA enforcement more transparent and compliance with the statute more understandable to the business community. Working closely with his counterparts at the U.S. Securities and Exchange Commission, Mr. Duross was one of the principal authors of the DOJ and SEC joint publication A Resource Guide to the U.S. Foreign Corrupt Practices Act, which followed a series of consultations with business and compliance leaders. The Guide has received wide praise from the business community, compliance and ethics professionals and private practitioners, and has been described as a “landmark document,” an “FCPA hornbook,” and a “must-read for compliance officers.”
Mr. Duross also served as DOJ’s principal representative to the Organisation for Economic Co-operation and Development’s Working Group on Bribery for many years and helped develop the OECD’s acclaimed Good Practice Guidance on Internal Controls, Ethics and Compliance. Besides his involvement in the OECD Phase 1 of Russia and Phase 2 of South Africa, Mr. Duross’s leadership during the OECD Phase 3 of the United States earned him the Assistant Attorney General’s Exceptional Service Award, the Criminal Division’s highest award for employee performance.
Prior to being appointed Deputy Chief, Mr. Duross served as Assistant Chief of the FCPA Unit from October 2008 to April 2010, and as a line prosecutor with the Fraud Section from December 2006 to October 2008. Beyond FCPA enforcement, Mr. Duross has supervised and tried all manner of white-collar cases, including healthcare fraud, mail and wire fraud, money laundering, public corruption, securities fraud and tax evasion. A veteran trial attorney, Mr. Duross is a recipient of the prestigious Attorney General’s Distinguished Service Award, the second-highest award for employee performance, as one of the lead prosecutors who secured the conviction of Congressman William Jefferson following a nearly nine-week trial.
Once dubbed “Mr. FCPA,” Mr. Duross has been repeatedly recognized by the Ethisphere Institute’s “Attorneys Who Matter” list, including most recently as a “Top Gun” based upon his expertise and experience. He has also been recognized by Chambers USA, Law360, the Legal 500 US, the Washington Post and the Washington Business Journal for his work on FCPA matters.
Mr. Duross earned his J.D., cum laude, from the University of Michigan Law School in 1996 and his B.A., magna cum laude, from the University of Michigan in 1993. After beginning his career as a litigation associate at an international firm in 1996 handling products liability and commercial litigation matters, he joined the U.S. Attorney’s Office for the Southern District of Florida in 2001, where he prosecuted a variety of white-collar cases, including bank fraud, embezzlement, mail and wire fraud, money laundering, securities fraud and trademark violations. Mr. Duross rose to the position of Deputy Chief in the Major Crimes Section in Miami before moving to Washington, D.C., in 2006 to join the Fraud Section. Mr. Duross is an adjunct professor at Georgetown University Law Center, where he teaches trial advocacy, has been a guest lecturer at Harvard Law School’s Program on the Legal Profession and the University of Michigan’s Ross School of Business and has served as an instructor of forensic examiner candidates at the FBI Laboratory in Quantico, Virginia. As an internationally recognized expert on transnational bribery, white-collar crimes, and compliance issues, Mr. Duross is a sought-after speaker, and he routinely speaks at conferences across the United States and around the world. He is admitted to practice in Michigan and the District of Columbia.