Edwards Wildman Palmer LLP
Steve is Chair of the White Collar & Government Enforcement Practice Group. He represents businesses and individuals in criminal and complex civil litigation, with a focus on white collar criminal defense and is experienced at conducting complex internal investigations, both in the United States and overseas. He regularly represents clients before the Securities and Exchange Commission and the Department of Justice. He also advises several publicly-traded companies on FCPA matters and has conducted training for those clients domestically and internationally. The Financial Times
has commended Steve for his innovative legal work in defense of a client.
After 17 years as a prosecutor with the Department of Justice, Steve applies his considerable experience to assisting corporations and executives with any government inquiries or internal investigations. Before joining the firm, Steve served for four years as Chief of the Public Corruption & Special Prosecutions Unit at the U.S. Attorney’s Office, District of Massachusetts, overseeing some of the most complex investigations in the office. He was one of the few Assistant United States Attorneys in Boston selected to work around the clock investigating the attacks of September 11. He also headed the federal inquiry into the Catholic Church sex abuse scandal. Prior to becoming Chief, he was part of the Economic Crimes Unit, where he prosecuted complex tax, health care fraud and investment fraud cases.
Steve has been a frequent lecturer at programs sponsored by the Boston Bar Association, the World Law Group and the Association of Corporate Counsel (ACC). While in the government, he lectured at the Department of Justice, IRS, and privately sponsored training seminars on the subjects of excise tax fraud, health care fraud, and financial prosecutions generally. He also has been a guest lecturer for the American Bar Association, Suffolk University Law School, Harvard Law School, the New England Institute of Law Enforcement, and the National Advocacy Center. Steve has been included in the New England Super Lawyers
listing, a Thomson Reuters
publication, since 2008.
- Represented audit committee of public company in internal investigation into government contract accounting practices.
- Represented public company in SEC Enforcement investigation triggered by purported whistleblower. Investigation terminated with no charges brought.
- Represented former President of Stryker Biotech in indicted federal health care fraud (off-label promotion) case. All charges dismissed. Commended by Financial Times for innovative legal work in this case.
- Counsels multi-national corporations on FCPA compliance issues.
- Has conducted FCPA training in Asia, Africa, Latin and South America.
- Represented fish wholesaler in Lacey Act prosecution.
- Represented data supply company in OFAC investigation regarding trade with Iran - No Action Letter received.
- Represented national Broker-Dealers in FINRA Reg SP enforcement action.
- Represented regional Broker-Dealer in Rhode Island Department of Business Regulation Enforcement matter.
- Represented Progress Software Corporation in SEC investigation into its stock option practices. No charges were brought.
- Represented American Tower Corp. in SEC and Department of Justice investigations into stock option practices. No charges were filed.
- Represented several publicly traded companies, Board Committees and individual Directors in stock option back-dating investigations by the Department of Justice and the S.E.C.
- Conducted internal investigations in Europe, China and Japan, as well as throughout the United States.
- Advised publicly traded company regarding FCPA issues and training in China.
- Conducted internal investigation into revenue recognition practices of publicly-traded company.
- Represented multiple universities regarding Attorney General investigations into lending practices.
- Represented the former CFO of a large hospital in an indicted matter.
- Represented several wholesalers in market-timing investigation.
- Represented several brokers in gifts and gratuities investigation.
- Represented pharmaceutical executives before a federal grand jury.
- Represented targets and witnesses in criminal tax investigations.
- Advised the Board of a medical device company as to compliance issues.
- Experienced in various federal courts and before the S.E.C. and FINRA.
Included in The Best Lawyers in America
publication in the field of white collar litigation.
Received the Department of Justice Award for Corporate Asset Forfeiture 2004, was the recipient of the Tax Division Outstanding Attorney Award for 1990, 1992, and 1996. He received the Attorney General letter of commendation in 1992 for work against organized crime elements in New York.
Recent Speaking Engagements and Publications
- "AP Records Seizure Fuels Push To Limit Gov't Snooping," quoted, Law360, May 16, 2013.
- "Collateral Consequences of Bribery: When Can Ethical Competitors Initiate Suit in the U.S. and U.K.?," co-author, The FCPA Report, May 15, 2013.
- "Last Name First Name Company Email Dinner Attended," quoted, The National Law Journal, May 2, 2013.
- "After hospital, where will Boston bombing suspect go?," quoted, NBC News, April 24, 2013.
- "Legal Teams Both Have Terror-Case Experience," interviewed, The Wall Street Journal, April 23, 2013.
- "Legal analyst: Death penalty is 'in play' in Boston bombing case," interviewed, NECN, April 22, 2013.
- "Thorny US legal questions swirl in case of suspect," quoted, The Boston Globe, April 21, 2013.
- "Boston Marathon case prosecutor known for aggressive record," quoted, Reuters, April 21, 2013.
- "Internal Investigations Done Right Obtaining a Non-Prosecution Agreement and Other ways to Protect Shareholders Value," panelist, Internal Investigations Done Right Obtaining a Non-Prosecution Agreement and Other ways to Protect Shareholders Value, Boston Bar Association, April 4, 2013.
- "Paying Bribes Abroad Will Get You in Hot Water in the US" co-author and speaker, Computer Magazine, February 2013.
- "Hacking defendant's suicide spurs debate over prosecutorial overreach," quoted, National Law Journal, January 14, 2013.
- "Internal Investigations," co-author, Edwards Wildman Guidance Note, January 2013.
- "Off-Label Promotion Is Not a Crime," co-author, Bloomberg BNA Pharmaceutical Law & Industry Report, December 21, 2012.
- "U.S. Export Laws and Related Trade Sanctions," co-author, Edwards Wildman Guidance Note, December 2012.
- "The Foreign Corrupt Practices Act," co-author, Edwards Wildman Palmer LLP White Paper, December 2012.
- "Pharmacy Case May See Call for Jail Time: US Prosecutor's Decision Awaited," quoted, Boston Globe, November 21, 2012.
- "Attention, Pharmaceutical and Medical Device Executives: Ignorance Is Not Bliss," co-author, Bloomberg BNA White Collar Crime Report, November 16, 2012.
- "The Department of Justice and the Securities and Exchange Commission Publish Long-Awaited Foreign Corrupt Practices Act Guidance," co-author, Edwards Wildman Client Advisory, November 2012.
- "Attention Pharmaceutical and Medical Device Executives – Ignorance is not bliss," co-author, Edwards Wildman Client Advisory, December 2012.
- "The Sword, a Shield, and Severance: The Corporate Attorney-Client Privilege in White Collar Criminal Prosecutions," co-author, Bloomberg BNA Criminal Law Reporter, August 2012.
- "The Foreign Corrupt Practices Act," co-author, Edwards Wildman Palmer LLP White Paper, July 2012.
- "US V. Spadoni — Document Retention Policy Is A Must," author, Law360, July 19, 2012.
- "Document Retention Policy Is A Must," author, Edwards Wildman Client Advisory, July 2012.
- “Are Sick Prisoners Getting the Care they Need,” interviewee, The Emily Rooney Show, WGBH, June 21, 2012.
- "Sal DiMasi says he was Denied Medical Treatment for Cancer in Prison," interviewee, Greater Boston, WGBH, June 21, 2012.
- "Former Mass. House Speaker Diagnosed with Stage 4 Cancer," interviewee, NECN, June 20, 2012.
- “Do I Need a Lawyer? If You Have to Ask, You Probably Do," co-author, Computer Magazine, May 2012.
- “Anatomy of a Health Care Fraud Case: Lessons from Stryker,” panelist, Health Care Fraud 2012, Boston Bar Association CLE Program, April 10, 2012.
- "Navigating the SEC's New Whistleblower Bounty Rules," speaker, Boston Bar Association, October 25, 2011.
- "Gatekeeper Liability Comes To Ireland," co-author, Law360, September 7, 2011.
- “Reminder: United Nations Officials are “Foreign Officials” Under the FCPA,” author, Edwards Angell Palmer & Dodge Client Advisory, July 2011.
- “Some FCPA Concepts are Coming into Focus: Implications for the UK Bribery Act,” author, Edwards Angell Palmer & Dodge Commercial Litigation Review, June 2011.
- “Is The DOJ Violating Cooperators' Rights?,” co-author, Law360, April 7, 2011.
- “Securities Enforcement: What's Up at the SEC: Whistleblowing, Insider Trading, and the FCPA,” moderator, The Foreign Corrupt Practices Act Panel, Boston Bar Association, April 6, 2011.
- “Is 2011 the Year for an SEC Crackdown on FCPA ‘Gatekeepers?',” co-author, Bloomberg Law Reports, March 2011.
- "Recent Government Enforcement Actions Regarding the Iranian Embargo Highlights the Hidden Risks of International Trade," co-author, Edwards Angell Palmer & Dodge LLP Client Advisory, March 2011.
- “Where Does His Co-Defendant’s Guilty Plea Deal Leave Sal DiMasi?,” speaker, The Emily Rooney Show, WGBH, March 8, 2011.
- “Where Do We Go From US Bank V. Ibanez?,” co-author, Law360, February 18, 2011.
- “IRS Announces New Voluntary Disclosure Program for Offshore Bank Accounts,” co-author, Edwards Angell Palmer & Dodge Client Advisory, February 2011.
- "Pay-to-play at sheriff's department," speaker, Fox Undercover Television Interview, January 10, 2011.
- "Suspicious Activity Reports: How and When to Write Them," co-presenter, webinar presented by Edwards Angell Palmer & Dodge, December 16, 2010.
- "Huggard Sees U.K. Anti-Bribery Act as 'Aggressive'," speaker, Bloomberg podcast, October 28, 2010.
- "The Brewing Foreclosure Crisis: Responding Effectively to Government Investigations," co-presenter, webinar presented by Edwards Angell Palmer & Dodge, October 28, 2010.
- "Bribery and Corruption Update: How a New UK Regime Will Impact US Companies, FCPA Developments, and Enforcement in China," speaker, seminar presented by Edwards Angell Palmer & Dodge LLP, Boston, Massachusetts and New York, New York, October 19 – 20, 2010.
- “Ethics in the Real World/Ethics and the Insurance Leader,” panelist, Association of Insurance Compliance Professionals’ 23rd Annual Conference, Dallas, Texas, October 6, 2010.
- "Securities Fraud Enforcement – the New Deal," speaker, Boston Bar Association's Securities Fraud 2010 CLE Program, April 6, 2010.
- "Foreign Corrupt Practices Act Compliance: Strategies for an Effective Global Program, Responding to Increased SEC and DOJ Enforcement," speaker, webinar, November 12, 2009.
- "Another Reason to Fear the Foreign Corruption Practices Act - The Private Tag-Along Suit," co-author, Bloomberg Law Reports, October 2009.
- "Managing Third-Party Relationships for Compliance," speaker, CBI's Leadership Summit on Global Interactions with Healthcare Providers, Arlington, Virginia, October 20 -21, 2009.
- "Business Crime Prosecutions Under the Obama Administration," seminar co-chair, MCLE, October 5, 2009.
- “En Banc First Circuit Decision Erodes Scope of the Work Product Doctrine,” co-author, Edwards Angell Palmer & Dodge Client Advisory, August 2009.
- "SEC Division of Enforcement Director Announces Aggressive New Initiatives," co-author, Edwards Angell Palmer & Dodge Client Advisory, August 2009.
- "The Anti-Corruption Battle: New Lessons from the Front Lines," panelist, Innovations & Strategies for Troubled Times: A Global Legal Update for U.S. Companies, a conference sponsored by the World Law Group, Washington, D.C., April 29, 2009.
- "The FCPA and International Anti-Corruption for the Insurance Industry," co-presenter, webinar presented by Edwards Angell Palmer & Dodge, April 20, 2009.
- "Securities Fraud 2009: Madoff, Trials, and the SEC's View on Enforcement," panelist, Boston Bar Association, February 10, 2009.
- "The FCPA & Doing Business Internationally: Compliant or Complaint," speaker, Edwards Angell Palmer & Dodge and the Association of Corporate Counsel (ACC) Greater New York Chapter, New York, June 26, 2008.
- "Voluntary Disclosure to the IRS: A Viable Option," author, Journal of Accountancy, March 2008.
- "Did the SEC Just Immunize Your Client? Economic Coercion Under Stein," co-author, Edwards Angell Palmer & Dodge, February 12, 2008.
- "Dealing with the New Realities of the Public Finance Market," speaker, seminar presented by Edwards Angell Palmer & Dodge LLP, Boston, Massachusetts, February 7, 2008.
- SEC Practice & Investigations: Views from Inside the SEC, Outside Counsel and Into the Future, panelist, Boston, Massachusetts, February 6, 2008.
- Foreign Corrupt Practices Act - Is Your Company at Risk, panelist, Boston, Massachusetts, November 15, 2007.
- "Don't Look Back: Stock Option Dating and Investigations 2007," moderator, seminar presented by the Criminal Law Section of the Boston Bar Association, February 7, 2007.
- "Our Money or Your Job," co-author, SumNews, Spring 2006.
- "Corporate FCPA Compliance Programs: A Necessity In Today's Aggressive Enforcement Environment," co-author, Edwards Angell Palmer & Dodge LLP Client Advisory, March 28, 2006.
- "Discovery more difficult and more vital in tech-enabled companies," Mass High Tech, February 6, 2006.
- "Tax Fraud Matters - Criminal and Civil Practice Pointers,” co-chair, Boston Bar Association, 2005.