Paul M. Krieger

+ EXPERIENCE

During his tenure as a federal prosecutor, Paul was appointed to lead two units within the SDNY’s Criminal Division. First, he served as Chief of the Narcotics Unit. He then served as a Chief of the Complex Frauds and Cybercrime Unit, where he oversaw the investigation and prosecution of sophisticated financial frauds, cybercrimes and cryptocurrency frauds, money laundering, Foreign Corrupt Practices Act (FCPA) violations, tax offenses, and healthcare fraud, including the cyber intrusion that resulted in the largest-ever theft of customer data from a U.S. financial institution, and the largest mortgage modification and debt collection schemes ever charged.

Paul also supervised the prosecutions of offshore financial institutions and international bank employees for tax offenses; the investigation of fraudulent initial coin offerings; the indictment of Iranian nationals for cyberattacks on multinational financial institutions; the indictment of Chinese nationals for obtaining and trading on confidential information obtained through breaching the servers of international law firms; the prosecution of a multi-million dollar fraud and kickback scheme committed by an executive at a publicly traded pharmaceutical manufacturer, and significant FCPA matters, including two of the Department of Justice’s largest criminal corporate bribery and corruption resolutions.

While at the U.S. Attorney’s Office, Paul conducted numerous high-profile public corruption and fraud trials, including the trials of a New York State Assemblyman and a former New Jersey State Senator for bribery offenses, and the trial of the chief compliance officer of the investment firm that managed the finances of the National Basketball Players Association. Paul also prosecuted a State Assemblyman for election law violations and false statements, and a consultant to the New York City Department of Education for embezzlement. In addition, Paul has briefed and argued numerous appeals before the U.S. Court of Appeals for the Second Circuit.

In recognition of the Complex Frauds and Cybercrime Unit’s consumer protection work during Paul’s tenure, the Federal Trade Commission awarded the group its 2016 Prosecuting Attorneys’ Award. In 2015, Paul received the Council of the Inspectors General’s Investigations Award for Excellence for the conviction of a special education provider who defrauded New York City of $4 million. Paul also has experience in complex civil proceedings, including matters involving contract and partnership disputes, insurance fraud, and cyber intrusions.

Prior to joining the U.S. Attorney’s Office, Paul practiced at Covington & Burling LLP and Davis Polk & Wardwell LLP, where he represented companies, individuals, and board committees in federal grand jury, SEC, state Attorneys General, and internal investigations concerning allegations of stock option manipulation, insider trading, and unlawful pharmaceutical sales and marketing practices. In addition, Paul served as a law clerk for the Honorable Denise L. Cote of the United States District Court for the Southern District of New York.

+ REPRESENTATIVE MATTERS

Government Enforcement / Investigations

• The president of a regional bank in an investigation by the DOJ and FDIC into allegations of BSA/AML violations.

• A hedge fund in an investigation by the SEC and DOJ into allegations of securities fraud and insider trading.

• Jury trial of medical biller charged by the DOJ with wire fraud, health care fraud, aggravated identify theft, and money laundering.

• A Special Committee of the Board of Directors of a publicly-traded analytics company in an internal investigation.

• The Board of Directors of two national, non-profit organizations in internal investigations.

• A European internet and technology company in an investigation by the DOJ and an internal investigation.

• A hedge fund in a FCPA prosecution being conducted by the DOJ.

• A pharmaceutical company in investigations by the DOJ and state Attorneys General into off-label sales and marketing practices.

• Members of the Board of Directors of a publicly-traded technology company in DOJ, SEC, and internal investigations into stock option manipulation.

• The CEO of a publicly-traded telecommunications company in an accounting fraud investigation being conducted by the SEC.

• The CEO of a defense contractor in connection with an internal investigation related to potential False Claims Act violations.

• An investment banking executive in an accounting fraud and securities fraud investigation being conducted by the DOJ and the SEC.

• A senior compliance officer at an international financial services firm in investigations being conducted by FINRA and the financial services firm.

• A senior executive at an international investigation firm in an investigation by the DOJ relating to allegations of fraud and misconduct.

• A physician in an indictment brought by the DOJ, which was ultimately dismissed.

Complex Commercial Litigation

• President of a university in a federal civil litigation arising out of an internal investigation.

• A company in a forfeiture investigation and civil proceeding brought by the Money Laundering and Asset Forfeiture Section of the DOJ.

• An international internet-retail company in cross-border litigation relating to an advertising campaign.

• An individual in civil and bankruptcy litigation concerning allegations of fraud and involving life insurance providers, brokers, and agents.

• A group of law firm partners in state court civil litigation concerning the dissolution of the law firm.

• An individual in a high-profile civil litigation in the Court of Appeals for the Second Circuit.

• Various financial professionals and executives in civil and associated litigation who have been the victims of cyber-intrusions and extortion attempts.

Crypto / Cyber Representations

• The Chief Compliance Officer of a financial services firm focused on digital currency trading and lending in an investigation by the DOJ and SEC.

• The compliance officer of digital asset mining and trading platforms in an investigation by the DOJ and SEC.

• A programmer and developer in connection with the launch of a cryptocurrency and crytpo exchange in an investigation by the DOJ.

• The independent compliance monitor in a FinCEN and CFTC monitorship of a cryptocurrency exchange.

• The founder and principal of a crypto trading and development firm in investigations by the DOJ, SEC, and CFTC and related civil litigation.

• An individual in connection with an investigation by the DOJ concerning the Ethereum blockchain.

• A principal of a crypto exchange and stablecoin issuer in connection with an investigation by the DOJ.

+ SPEAKING ENGAGEMENTS

• “Representing Individuals Facing Investigations” (Cambridge Forum on Risk Regulation & Enforcement in FinTech, May 14, 2024)

• “Facial Recognition, Decryption, and Your Personal Data: A Look Into Law Enforcement Technologies and Their Impact on Privacy Rights" (Federal Bar Council Fall Retreat, November 2, 2019)

• “The Impact of Aggressive National and Multinational Enforcement of Anti-Corruption Laws in Brazil” (Conference hosted by Pinheiro Guimarães and KKL in São Paulo, Brazil, December 6, 2018)

• “Shell Companies and BSA Issues Related to Cybersecurity / SAR Reporting” (Advanced BSA/AML Specialist Conference hosted by the Federal Financial Institution Examinations Council, July 17, 2018)

• “Securing Consumer Data in Today’s Cyber Threat Landscape” (Comply 2018 – The RegTech and Compliance Conference, May 17, 2018)

• “White Collar Enforcement Trends Under the Trump Administration” (American Bar Association Annual Meeting in New York, August 10, 2017)

• “Fraud in Employee Benefit Plans and Trusts” (11th Mid Atlantic Anti-Money Laundering Conference, August 7, 2017)

• “Avoiding Shareholder Action: How to Integrate All Internal Stakeholders into the Cyber Risk Governance Defense” (Skytop Strategies, March 16, 2017)

• “Hot Topics in Cyber Risk: Regulation, Compliance, and Enforcement Trends; Third Parties Under Fire; Cyber Risk Governance and Insider Threat Management” (Sandpiper Partners, January 26, 2017)

• “Towards Darkness or Light? Balancing Liberty and Security in the Fight Against Cybercrime” (Federal Bar Council, January 18, 2017)

• “DOJ’s New FCPA Pilot Program and Current Enforcement Trends” (Protiviti, May 13, 2016)

• “Second Annual Information Governance, Security, and Privacy Briefing” (Sandpiper Partners, May 4, 2016)

• “Enforcement 2016: Perspectives from Government Agencies – Ethics Panel” (Practicing Law Institute, April 29, 2016)

• “Global Cities Joining Forces Against Corruption – Game-Changing Cases: An Inside Look at Breakthrough Investigations” (Columbia Law School – Center for the Advancement of Public Integrity, April 24, 2015)