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Cleary Law Firm Bolsters White-Collar Practice with Former DOJ Foreign Bribery Chief
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Cleary Gottlieb Steen & Hamilton, a renowned law firm based in New York, has recently made a strategic addition to its white-collar practice in Washington, D.C. On Monday, The firm announced that it hired David Last, a senior official from the U.S. Justice Department, who oversaw foreign bribery cases as the chief of the department’s Foreign Corrupt Practices Act (FCPA) unit. Last’s role as a partner at Cleary will primarily focus on government enforcement and internal investigations, specializing in matters related to the FCPA, which prohibits American companies from engaging in bribery to secure business opportunities abroad.

Cleary’s decision to bring in David Last stems from his extensive experience and expertise in handling criminal FCPA investigations and prosecutions. During his tenure as the unit chief, Last was responsible for managing all such cases, including notable achievements such as securing a $700 million penalty against Glencore, a major multinational commodity trading company, and securing the conviction of Roger Ng, a former Goldman Sachs banker. Last’s track record and deep understanding of the FCPA make him an invaluable asset to Cleary’s white-collar practice.

In expressing his excitement about joining Cleary, Last emphasized the firm’s global presence as a perfect fit for a practice that deals with cross-border matters. Cleary, founded in New York, has established a strong reputation for representing leading financial institutions and operates with a vast network of 1,100 lawyers spread across 16 offices worldwide. This extensive reach and global perspective align well with Last’s focus on international cases involving the FCPA.


Having spent 17 years at the Justice Department, including his initial role as a prosecutor in the U.S. Attorney’s Office in Washington, D.C., Last brings a wealth of knowledge and insight to Cleary. His deep understanding of the inner workings of the Justice Department and his involvement in evaluating the department’s policies on corporate crime further enhance his ability to navigate complex legal landscapes.

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The increased enforcement of the FCPA by U.S. prosecutors over the past 15 years has led to significant corporate cases and a rising demand for legal experts in anti-corruption matters. Major law firms are actively seeking professionals with specialized knowledge in this field. Last’s appointment at Cleary highlights the firm’s commitment to staying at the forefront of white-collar practice, as it recognizes the importance of having lawyers well-versed in FCPA enforcement and compliance.

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Last’s role extends beyond his expertise in FCPA matters. He was also part of a committee responsible for evaluating the Justice Department’s policies on corporate crime, leading to a series of changes last year aimed at encouraging companies to self-report misconduct to the government. Last believes that these policy updates provide companies with a clear path to approach the DOJ and disclose any wrongdoing, provided the circumstances are appropriate. This development offers companies valuable considerations when contemplating self-disclosure and cooperating with the authorities.

Although the number of FCPA enforcement actions has seen a decline in the past three years, Last suggests that there is still an active pipeline of investigations underway. He anticipates a significant increase in enforcement activity by the end of the year, signaling that there will be noteworthy developments in this space. The ongoing scrutiny of corporate conduct highlights the need for skilled attorneys who can guide companies through potential legal challenges and ensure compliance with anti-corruption regulations.

Cleary’s addition of David Last to its white-collar practice demonstrates the firm’s commitment to providing exceptional legal services to its clients. By bringing in a seasoned professional with extensive experience in FCPA enforcement, Cleary aims to reinforce its position as a leading firm in white-collar defense and internal investigations. With Last’s insights and expertise, the firm is well-equipped to handle complex cross-border matters and provide comprehensive counsel to companies navigating the intricacies of the FCPA and other relevant regulations.

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