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DOJ's Growing Enforcement: Are Tips and Terror Designations Fueling Cases?

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William Frentzen, Brian Michael, Christine Wong, and Rodrigo Bermudez published an article in the Daily Journal's Top White...

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<p>We are Morrison Foerster — a global firm of exceptional credentials. Our clients include some of the largest financial institutions, investment banks, and Fortune 100, technology, and life sciences companies. Our lawyers are committed to achieving innovative and business-minded results for our clients, while preserving the differences that make us stronger.</p><p>Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations. Prior results do not guarantee a similar outcome.</p>

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<p>William Frentzen, Brian Michael, Christine Wong, and Rodrigo Bermudez published an article in the <em>Daily Journal'</em>s Top White Collar supplement that discussed recent developments in the Department of Justice's (DOJ) approach to corporate criminal enforcement, namely the launch of its Corporate Whistleblower Awards Pilot Program and the Trump administration's designation of eight cartels as Foreign Terrorist Organizations.</p><p>The authors wrote, "While still in its early days, given the DOJ's stated commitment to white-collar criminal enforcement coupled with other policy goals focused on cartels, along with a possible growing backlog of actionable tips of corporate misconduct, federal prosecutors may be poised to bring a new wave of corporate enforcement investigations and cases in the near future. Not taking them seriously now could present a company with real peril down the road if the DOJ follows through with action."</p><p>Read the <a href="https://www.dailyjournal.com/articles/388948" target="_blank">full article</a> (subscription required).</p>

<p>DOJ's Growing Enforcement: Are Tips and Terror Designations Fueling Cases?</p>

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<p>William Frentzen, an accomplished trial lawyer who formerly served as chief of the Corporate and Securities Fraud Unit for the U.S. Attorney’s Office for the Northern District of California (NDCA), is a partner in Morrison Foerster’s Trial and Investigations + White Collar Defense Groups.</p><p>William represents companies and their executives in internal and government investigations, white collar criminal defense matters, and parallel civil litigation related to allegations of corporate fraud, securities fraud, public corruption, intellectual property crimes, crisis response related to cyber breaches, money laundering, healthcare fraud, digital currency crimes, tax crimes, cybercrime, Racketeer Influenced and Corrupt Organization (RICO) Act violations, and environmental crimes, among others.</p><p>Over the course of his career, William has successfully tried over 40 federal criminal and civil jury trials around the country, including some of the longest and most complex criminal cases in the NDCA. His trial capabilities were recognized through his appointment as senior trial counsel for the NDCA, a position created in acknowledgment of William’s unique ability to try cases. He has never lost a jury trial in which he served as first-chair. William’s trial experience includes securing conviction of a chief financial officer related to accounting and securities fraud charges arising out of the $11 billion sale of a software company, the largest fraud case in the history of the NDCA. He has also achieved several high-profile criminal resolutions, including the first-ever criminal prosecution for violating the Lobbying Disclosure Act against an infamous lobbyist and the conviction of two corrupt federal agents for stealing and extorting digital currency during their investigation of the Silk Road dark market website. He also served as an adjunct professor at UC Berkeley School of Law, where he taught civil trial practice.</p><p>William has represented cryptocurrency platforms and other companies through exploit and cybersecurity attacks and asset recovery, including representing a company through the largest digital asset recovery in decentralized finance history. He also serves as an advisor for the capital fund of Haun Ventures, an investment firm focused on web3 ventures, tokens, and projects related to blockchain technology, digital currency, and crypto assets.</p><p>Before joining MoFo, William spent over 20 years at the U.S. Department of Justice (DOJ), where he most recently served as chief of the Corporate and Securities Fraud Unit for NDCA. Prior to that he served as chief of the Corporate Fraud Strike Force, as senior trial counsel, and as chief of the Organized Crime Strike Force for that office, and he also developed and supervised the country’s first cryptocurrency crime coordinator position within a U.S. Attorney’s Office. William has also served as an assistant United States attorney (AUSA) in the U.S. Attorney’s Offices for the District of Columbia and the Southern District of Georgia and as associate independent counsel in the Office of Independent Counsel.</p><p>Since joining private practice, William has been recognized by leading industry and business publications, including <em>Financial Times</em>, which named him a “Commended Individual” in the Innovative Lawyers in Cyber Security & Data Protection category of its 2023 North America Innovative Lawyers report. He was recognized for his role in negotiating the return of nearly $200 million in digital assets for Euler, three weeks after these assets were stolen, completing one of the largest recoveries in decentralized finance history. Further, William was named to <em>Daily Journal</em>’s 2024 list of Leading Commercial Litigators relating to the successful handling of multiple civil litigation matters, including a jury trial victory, two granted summary judgment motions, and his work on the Euler matter mentioned above.</p><p>William also received numerous awards for his exceptional trial work at DOJ, including, among others, the Attorney General’s Distinguished Service Award, the DOJ Director’s Award for Superior Performance by a Criminal AUSA, and the FBI Director’s Award for Excellence, in addition to various other awards and commendations from federal and state agencies. He was also recognized as a California Attorney of the Year by <em>The Recorder</em> following a five-month racketeering jury trial.</p><p>Throughout his time as a prosecutor, William has coordinated with a variety of state, local, and federal law enforcement partners, including the U.S. Securities Exchange Commission (SEC), Federal Bureau of Investigation (FBI), Internal Revenue Service (IRS), Commodity Futures Trading Commission (CFTC), Federal Trade Commission (FTC), Office of Foreign Assets Control (OFAC), and Financial Crimes Enforcement Network (FinCEN), among others. He has also worked with numerous global law enforcement agencies, including INTERPOL, Europol, the UK Serious Fraud Office, and the UK National Crime Agency, among others.</p><p>William received his J.D. cum laude from Tulane Law School, where he also received a certificate in environmental law, and his B.A. from New College of the University of South Florida.</p><h4>Representative Experience</h4><h5>Private Litigation Experience</h5><ul><li>Obtained a rare jury verdict in a Clean Water Act trial in the Central District of California involving allegations of years of runoff into navigable waters, applying a recent Supreme Court decision regarding pollution point sources.</li><li>Obtained a complete defense victory through summary judgment for a leading transportation technology company against a prominent venture capital fund that alleged fraud and contractual interference.</li><li>Secured a favorable settlement after jury selection in a trial for a major biosciences company and founders, executives, and board members in a lawsuit filed in San Diego Superior Court alleging fraud, breach of contract, and tortious interference claims, which sought damages of $400–700 million.</li><li>Negotiated the return of more than $220 million in digital assets for a leading decentralized finance (DeFi) platform, three weeks after these assets were stolen, completing one of the largest recoveries in DeFi history.</li><li>Representing OpenAI and two current executives in a claim for breach of contract, promissory estoppel, breach of fiduciary duty, and unfair competition brought by Elon Musk.</li><li>Representation of a DeFicrypto exchange in relation to a major exploit resulting in the misappropriation of over $110 million, including negotiating return of most of the funds; assisting in identifying the attacker, leading to his conviction; and bringing a lawsuit against the attacker for return of remaining funds.</li><li>Representation of a technology company through discovery and repair of a defect that could have been exploited to adversely impact customers and result in litigation but was handled in a manner avoiding any impact to customers.</li><li>Negotiated the safe return of Tigran Gambaryan, a former decorated IRS Criminal Investigations agent who was unlawfully lured, detained, and prosecuted by the Nigerian government. The matter involved coordination with local counsel in Nigeria as well as other law firms and entities in the United States to raise awareness of his detention, bring pressure for his release, craft his legal strategy and trial defense, and pursue legal recourse against those who unlawfully detained him. All charges were dismissed against the client.</li><li>Representation of technology company against allegations of false advertising by City Attorney’s Offices. Representation concluded without any claims being brought against the client.</li><li>Representation of companies and executives through investigations by the U.S. Department of Justice. Representations concluded without charges being brought against the client.</li><li>Representation of companies and executives in regulatory investigations and cases investigated and brought by the CFTC and the SEC.</li><li>Representation of companies through investigations by state and local law enforcement.</li><li>Representation of companies in highly sensitive matters involving internal fraud investigations and involuntary and negotiated departures of the chief executive and other senior officers.</li></ul><h5>Government Experience</h5><ul><li>Brought accounting and securities fraud charges against a chief executive officer, chief financial officer, and founder arising out of the $11 billion sale of a software company, which led to the conviction of the chief financial officer and became the largest fraud case in the history of NDCA.</li><li>Brought money laundering, conspiracy to commit international money laundering, and operating an unlicensed money exchange charges against an unregistered digital currency exchange, BTC-e, and its primary operator. Brought novel charges for the infamous hack of the Mt. Gox cryptocurrency exchange.</li><li>Seized billions of dollars in digital currency, one of the largest seizures in U.S. history, related to the Silk Road digital black-market platform.</li><li>Brought money laundering, computer intrusion, and conspiracy to commit wire fraud charges against the perpetrators of a major cyber breach involving VIP customer accounts of a large social networking service and cryptocurrency fraud. This was one of the most rapidly investigated and charged cyber incidents of recent times.</li><li>Conducted an investigation into conspiracy to commit money laundering and conspiracy to distribute narcotics into the largest and longest-running darknet market, Hydra Market, which accounted for approximately 80% of all cryptocurrency transactions on the darknet generally.</li><li>Brought securities fraud charges against an online cryptocurrency investment manager and its principal related to a fraudulent investment scheme valued at $20 million.</li><li>Brought theft of trade secrets charges against the chief engineer of a multinational transportation company regarding the misappropriation of self-driving vehicle technology.</li><li>Brought public corruption charges against the heads of various municipal and public utilities operations in California.</li><li>Brought bribery and honest services charges against a California state senator and organized crime and RICO charges in one of the most significant organized crime cases in history, involving the infamous Raymond “Shrimp Boy” Chow.</li></ul><h4>Memberships</h4><ul><li>The Bar Association of San Francisco, Criminal Law Section, Executive Committee Member</li></ul>

William Frentzen

Partner

<p>Brian R. Michael is a partner in Morrison Foerster’s Investigations + White Collar Defense Group, and the chair of the firm’s Global Ethics + Compliance practice.</p><p>Recognized as one of the top lawyers in California, Brian draws upon more than 25 years of high-profile experience in private practice, as an in-house leader, and as a federal prosecutor in the Southern District of New York and the Central District of California to represent entities and individuals who turn to him for the most complex, high-stakes white collar criminal cases, internal and government-facing investigations, securities and regulatory enforcement matters, and related litigation and trials. Brian routinely advises clients on a wide range of matters involving corporate and securities fraud, the Foreign Corrupt Practices Act and global anti-corruption laws, workplace misconduct, public corruption, cybersecurity, FinTech and blockchain technologies, trade sanctions, whistleblowing, and human rights and supply chain due diligence, among other areas.</p><p>Brian’s practice also focuses on providing sensitive crisis management and compliance counseling, and he has extensive experience leading the design, enhancement, and implementation of cross-border compliance programs. He regularly leads global risk assessments and provides compliance and crisis preparedness training to companies, boards, and employees.</p><p>In addition to his many years in private practice, Brian served as Deputy General Counsel and Group Chief Compliance Officer at media and entertainment company 21st Century Fox, and as an Assistant United States Attorney in both the Southern District of New York and the Central District of California. At 21st Century Fox, Brian played a critical role in the company’s response to multiple cross-border investigations, including the “UK phone hacking” crisis and the wide-ranging FIFA corruption matter, and oversaw global compliance for Fox broadcast, cable, digital, and sports media businesses, including National Geographic Partners and more than 300 channels in over 180 countries. As a federal prosecutor, Brian tried numerous cases and briefed and argued multiple appeals, as well as led criminal investigations and prosecutions involving complex financial, securities, and healthcare fraud, cybercrime, organized crime and racketeering, money laundering, violent crime, child sexual exploitation, and asset forfeiture, for which he received many commendations and awards. Brian also served as the Violence Against Women Act Coordinator and the Anti-Gang Coordinator for the Central District of California.</p><p>After graduating law school, Brian clerked for former Chief Judge Gilbert S. Merritt of the U.S. Court of Appeals for the Sixth Circuit.</p><p>Brian is a frequent public speaker and commentator on investigations, white collar crime, securities and regulatory enforcement, and compliance topics. He serves on the Board of Advisors for Vanderbilt Law School and on the Executive Committee of the Board of Directors for Teach Democracy, a non-partisan nonprofit dedicated to advancing civics education and engagement among largely underserved youth. He is also a member of the Board of Directors of the Southern California Regional Subcommittee of the ABA’s White Collar Crime Committee and a Fellow of the American Bar Foundation.</p><p>Brian earned his B.A. with distinction in general scholarship from the University of California at Berkeley and earned his J.D. from Vanderbilt Law School, where he was elected Order of the Coif.</p><h4>Representative Experience</h4><h5>Government-Facing Investigations</h5><ul><li>Representation of a national governing body for an Olympic sport in an investigation led by the California Attorney General’s Office into historical allegations of sexual misconduct and abuse by local affiliates, resulting in successful resolution with no adverse findings.</li><li>Representation of a global auto manufacturer in connection with an investigation by the U.S. Attorney’s Office for the Central District of California into alleged foreign bribery and the prosecution of a former employee, successfully resulting in no adverse action against the company.</li><li>Representation of a prominent nonprofit entity in an internal investigation into multiple complaints regarding conflicts of interest, self-dealing, and other significant misconduct committed by top-level executives, resulting in successful separation of the executives on favorable terms for client.</li><li>Representation of a world-leading publisher of online video content in an investigation led by the New York Attorney General’s Office into alleged violations of state law regulating the nature of online content, resulting in successful outcome with no adverse action.</li><li>Representation of prominent private high school in Los Angeles embroiled in the Varsity Blues college admissions scandal, across from the U.S. Department of Justice.</li><li>Representation of a lobbyist in connection with a high-profile and wide-ranging corruption probe of the Los Angeles City Council led by the U.S. Attorney’s Office for the Central District of California, successfully resulting in no criminal action against client.</li><li>Representation of a fund and its three managing members in connection with investigations led by the U.S. Attorney’s Office for the Central District of California and the SEC related to a $500+ million Ponzi scheme and the prosecution of the perpetrator in the largest Hollywood Ponzi scheme ever, successfully resulting in no criminal or civil enforcement actions; featured in a lead story in <em>The New Yorker</em>, CNBC’s <em>America Greed</em>, and multiple documentaries, podcasts, and other publications.</li><li>Representation of senior executives for multiple entities in connection with U.S. Department of Justice criminal and civil enforcement investigations, and related FDA proceedings, related to COVID-19 testing protocols and devices.</li><li>Representation of a high-profile individual in connection with asset forfeiture and related proceedings concerning the 1MDB criminal prosecution in the Eastern District of New York.</li><li>Representation of a former senior research scientist of a multinational life sciences company in an internal investigation and parallel FDA investigation regarding alleged research misconduct by the former CEO in relation to the then-most expensive drug therapy ever, resulting in no enforcement action.</li></ul><h5>Internal and Board Investigations</h5><ul><li>Engaged by the California Department of Justice’s (DOJ) Office of the Attorney General to lead and conduct an independent review of DOJ’s public release of confidential personal information associated with firearms permit holders and applicants, and to prepare and release a public report setting forth detailed factual findings regarding the data release and recommendations for remedial actions.</li><li>Representation of a public multinational media company in multiple highly sensitive internal investigations into manipulation and tampering by third parties of core business activities and information, resulting in successful disruption and cessation of the improper activities and preservation of company’s business integrity.</li><li>Representation of a global auction house in an internal investigation of misconduct by senior executive and advising company leadership and board on mitigation and remediation arising from investigative findings.</li><li>Representation of a global FinTech entity in investigating alleged financial misconduct in Asia-Pacific region that came to light during due diligence for a time-sensitive and significant transaction, resulting in the successful closing of the transaction.</li><li>Representation of CEO and founder of prominent digital media company in board investigation of allegations of misconduct from co-founder, resulting in successful determination that allegations were unfounded.</li><li>Representation of senior public university executive in an investigation arising from whistleblower allegations of misconduct directed towards university’s leadership, resulting in successful finding of no wrongdoing.</li></ul><h5>Compliance Counseling, Crisis Management, and Due Diligence</h5><ul><li>Representation of a global FinTech entity in the design and implementation of a global compliance infrastructure related to the successful roll-out of a new payment tool.</li><li>Led crisis response for prominent investment funds in response to racially charged incidents at real estate developments in the wake of the George Floyd incident, resulting in successful resolution of the conflicts.</li><li>Led due diligence for prominent hedge fund in connection with potential/successful deal activity.</li></ul><h5>Complex Litigation and Trials</h5><ul><li>Representation of high-net-worth individual in dispute over distribution of significant marital estate in litigation across from former spouse, resulting in successful resolution for client.</li><li>Representation of a high-profile professional athlete in mediation and litigation across from former spouse regarding sensitive personal matters.</li><li>Representation of prominent Hollywood executive in connection with termination due to allegations of misconduct and subsequent successful arbitration resulting in finding that termination was unlawful, along with significant financial recovery for client.</li><li>Defense of a global auto manufacturer in consumer fraud litigation across California, including extensive trial preparation for multiple cases the led to successful resolution on favorable terms for client.</li><li>Representation of healthcare executive in complex financial dispute across from multiple insurance carriers, resulting in mediated settlement and dismissal of action.</li></ul>

Brian Michael

<div class="videoWrapper"><span class='youtube-wrapper'><iframe class="sticky-video" title="Meet MoFo San Francisco Litigation Partner Christine Wong" src="https://www.youtube-nocookie.com/embed/27P0I7oxkbc?rel=0" frameborder="0" allow="autoplay; encrypted-media" allowfullscreen="1" title="iframe"></iframe></span></div><p dir="ltr">Christine Wong focuses her practice on investigations, white collar criminal defense, and cross-border compliance matters. Christine draws on her unique background as an internal advisor and as a federal prosecutor in advising companies, boards and executives in a variety of matters that present significant legal and reputational risk – including white collar criminal and regulatory enforcement, internal investigations and related civil litigation. She also provides ongoing compliance advice to corporate clients. Christine has an active trial practice as first chair in both criminal and civil cases. </p><p>Christine is a former co-chair of MoFo’s Global Litigation Department and the firm’s Securities Litigation, Enforcement, and White Collar Defense practice group. She also served as an Adjunct Professor at UC Berkeley School of Law, where she taught Civil Trial Practice. Christine served as a federal prosecutor for the Southern District of New York and the Northern District of California, where she investigated a wide range of matters including public corruption, fraud, and organized crime, and served as lead counsel in over a dozen jury trials. She briefed criminal appeals before the United States Court of Appeals for the Ninth Circuit and the United States Court of Appeals for the Second Circuit.</p><p>Christine is regularly recognized by leading industry publications such as <em>Legal 500 US</em> in its Corporate Investigations and White Collar Defense category and <em>Chambers USA</em>’s (California) Litigation: White Collar Crime & Government Investigations category. Clients have highlighted Christine’s “exceptional and unique background combining DOJ experience, in-house experience, handling complex investigations and negotiations with government agencies,” and noted that she is “responsive to all levels and her team command is second-to-none.” Christine has also been included in <em>Daily Journal</em>’s 2025 Top 100 Lawyers list, highlighted in <em>Global Investigations Review</em>’s 2025 Women in Investigations series, recognized as a “Best Lawyer” in Criminal Defense: White Collar by <em>Best Lawyers in America</em>, and named among <em>Lawdragon</em>’s 500 Leading Global Crisis Management Lawyers.</p><p>Before joining MoFo, Christine led the development and implementation of the global compliance program for a Fortune 500 multinational corporation, where she served as vice president, head of international compliance. In that capacity, she conducted risk assessments for dozens of entities, which resulted in enacting necessary amendments to business workflows and policies. She was responsible for managing investigations and related litigation, reviewing policies and procedures, developing and delivering training modules, and ultimately reporting to the board of directors.</p><p>Christine speaks conversational Mandarin and Cantonese.</p><h4>Representative Experience</h4><ul><li>Representing Hawaiian Telcom in all matters arising from the 2023 Maui Wildfires.</li><li>Representing a waste management company in negotiating a deferred prosecution agreement with the DOJ and the resolution of a parallel civil lawsuit filed by local authorities related to a public corruption investigation.</li><li>Representing Pacific Gas and Electric Company in investigations by the Safety and Enforcement Division of the California Public Utilities Commission and related proceedings pertaining to wildfires.</li><li>Defending a Chinese semiconductor company indicted for theft of trade secrets and economic espionage.</li><li>Representing employees of a company in an accounting and securities fraud investigation.</li><li>Obtaining a declination for an individual in a criminal tax fraud investigation.</li><li>Representing a senior executive in an accounting fraud investigation by the DOJ and the SEC.</li><li>Counseling a multinational information technology equipment and services company on anti-bribery, antitrust and export control compliance.</li><li>Counseling a multinational entertainment company on anti-bribery training, policies and procedures.</li></ul><h4>Professional Memberships</h4><ul><li>American Bar Association, Criminal Justice Section, White Collar Crime Committee, Vice-Chair</li><li>Women in White Collar Defense Association, Committee Member of the San Francisco Chapter</li><li>American Bar Association Northern District of California White Collar Subcommittee, Committee Member</li></ul>

Christine Wong

<p><em>Daily Journal</em></p>