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Ephraim (Fry) Wernick
Ephraim (Fry) Wernick
Partner — Government Investigations & White Collar Criminal Defense
Partner — Government Investigations & White Collar Criminal Defense

Ephraim (Fry) Wernick

Ephraim (Fry) Wernick
Washington, D.C.

2200 Pennsylvania Avenue NW
Suite 500 West
Washington, D.C. 20037

Dallas

Trammell Crow Center
2001 Ross Avenue
Suite 3900
Dallas, Texas 75201

start quote symbolMy clients know that I am on their team and that their problems are my problems, and most importantly, that I will fight for them every step of the way.end quote symbol
Ephraim (Fry) Wernick

Experience Highlights

  • Represent a financial services and fintech company in litigation against the Consumer Financial Protection Bureau and New York Attorney General’s Office, currently pending in the U.S. District Court for the Southern District of New York

  • Represent and lead an internal investigation by a multinational private equity fund in connection with a U.S. Department of Justice investigation into alleged violations of the Foreign Corrupt Practices Act in Brazil

  • Represent foreign nationals in contested forfeiture proceedings against the U.S. Department of Justice, Money Laundering and Asset Recovery Section and the U.S. Attorney’s Office for the Central District of California concerning alleged corruption and money laundering and attempted forfeiture of a $53 million property in Los Angeles

  • Represent an individual in connection with the U.S. Department of Justice Special Counsel investigation into alleged obstruction and interference in the 2020 Presidential Election

  • Represent a senior executive in connection with an investigation into alleged sanctions violations by the U.S. Attorney’s Office for the Southern District of Texas

  • Represent a healthcare company and senior executive in connection with an investigation by the U.S. Attorney’s Office for the Eastern District of Virginia

  • Represent an individual in connection with an investigation into alleged healthcare and securities fraud by the U.S. Attorney’s Office for the Eastern District of New York

  • Represent an individual in contested forfeiture and restitution matters currently pending in the U.S. District Court for the Southern District of California

  • Successfully represented a financial services and fintech company through a DPA and corporate monitorship with the U.S. Department of Justice

  • Successfully resolved a settlement on behalf of a financial services company with the New York Department of Financial Services

  • Represent multiple individuals in connection with an ongoing FCPA investigation in Latin America by the U.S. Department of Justice and the Securities and Exchange Commission

  • Represent a social media company in connection with an investigation by the Select Committee to Investigate the January 6th Attack on the United States Capitol

  • Represent a precious metals company in connection with an investigation by the SEC

  • Represent a major university system and research laboratory in connection with multiple congressional and state legislative investigations into the origin of the COVID-19 pandemic

  • Represent a privately held group of companies in connection with an internal investigation and prosecute a civil lawsuit involving a $47 million fraud

  • Conduct an internal investigation into the theft of valuable NFTs and the use of cryptocurrency

  • Represented a publicly traded financial services and infrastructure company in connection with ongoing FCPA investigations in Latin America by the U.S. Department of Justice and the Securities and Exchange Commission

  • Conducted a risk assessment and implementation of compliance enhancements for a publicly traded technology company

  • In a pro bono matter, represent a female Afghan judge and her family in connection with their successful escape from Afghanistan and relocation to a third country after the U.S. withdrawal

  • Conducted a risk assessment and implementation of compliance enhancements for an international manufacturing company

  • Represented a major university system and multiple educational institutions in connection with investigations by Congress and the U.S. Department of Education into alleged violations of Section 117 of the Higher Education Act

  • Represented an individual in connection with a high-profile Congressional investigation into improper delivery of COVID-19 vaccinations

  • Represented a private equity firm and portfolio energy company in connection with an internal investigation into alleged campaign finance violations

  • Represented a publicly traded transportation company and managed an internal investigation into allegations of corruption and financial fraud

  • Represented a large IT services and solutions contractor and managed an internal investigation into allegations of retaliation and substantive violations of the False Claims Act by a former employee

  • Represented South Korean food distributor in connection with victim restitution claims under the Mandatory Victim Rights Act

  • Represented a U.S.-based importer and its CEO in connection with an investigation by the U.S. Secret Service into alleged PPE fraud

  • Represented a publicly traded energy company and conducted a compliance review prior to the execution of a large merger

  • Represented a publicly traded space technology company in connection with a comprehensive compliance review and implementation of risk-based enhancements to the program

  • Supervised a high-profile FCPA and money laundering investigation, including charges against two senior bank executives and an intermediary, for their alleged role executing a multi-billion dollar bribery and embezzlement scheme

  • Supervised the prosecution in U.S. v. Mobile Telesystems PJSC; the coordinated resolution between DOJ and the SEC resulted in a parent-level DPA and subsidiary-level guilty plea, an $850 million criminal fine, and a three-year corporate monitorship for a Russian telecommunications company that paid over $420 million in bribes in Uzbekistan

  • Lead trial attorney in U.S. v. Telia Company AB, et al; the coordinated resolution between DOJ and the SEC, the Netherlands, and Sweden resulted in a parent-level DPA, subsidiary-level guilty plea, and a $965 million criminal fine for a Swedish telecommunications company that paid over $330 million in bribes in Uzbekistan

  • Lead trial attorney in U.S. v. Rolls-Royce plc, et al; the coordinated resolution between DOJ and the U.K. Serious Fraud Office and Brazil Public Prosecutor resulted in a parent-level DPA and $880 million global fine, and seven individuals were also charged in connection with their role in a conspiracy to pay and launder over $80 million in bribes in six different countries

  • Lead trial attorney in U.S. v. VimpelCom, Ltd. et al; the coordinated resolution between DOJ and the SEC and the Netherlands resulted in a parent-level DPA, subsidiary-level guilty plea, a subsidiary guilty plea, a $835 million criminal fine, and a three-year monitorship for a Dutch telecom company that paid over $114 million in bribes in Uzbekistan

  • Lead trial attorney in a national security counter-intelligence and FCPA prosecution of a Russian official, a U.S. company, and U.S. businessmen for conspiring to pay and launder over $2 million in bribes in connection with the transportation of nuclear fuel between the Russian Federation and the United States, yielding three FCPA-related pleas and a corporate NPA

  • Supervised the prosecution in U.S. v. Credit Suisse (Hong Kong) Ltd.; the coordinated resolution between DOJ and the SEC resulted in an NPA and $47 million criminal penalty for corrupt hiring practices in Asia

  • Supervised a major oil and gas investigation involving a coordinated prosecution with five foreign jurisdictions into approximately 15 oil and gas companies that used a corrupt intermediary company to bribe foreign officials in the Middle East, Africa, and Asia

  • Supervised a major aerospace investigation involving a coordinated prosecution with multiple jurisdictions into bribery and ITAR Part 130 violations

  • Supervised an investigation into corrupt practices in professional sports, including alleged bribery, visa fraud, sanctions evasion, and extortion by teams operating in Latin America

  • Served as a DOJ subject matter expert, delegate and negotiator on anticorruption, asset recovery, and trade matters at multiple international fora, including the Organization for Economic Co-Operation and Development (OECD) in Paris; the United Nations General Assembly in New York, the U.N. Convention Against Corruption in Vienna; and was a U.S. negotiator for the anticorruption component of NAFTA 2.0

  • Served a one-year detail to DOJ’s Guantanamo Bay Litigation Team, where he investigated and litigated cases on behalf of the U.S. against prisoners of war and high-value detainees connected to the Taliban, al-Qaida and associated groups, and was the lead trial attorney in Khairulla Khairkhwa v. Obama, which resulted in the continued detention of the highest ranking member of the Taliban in U.S. custody at Guantanamo Bay, Cuba

  • Served as Counsel on the U.S. Senate Permanent Subcommittee on Investigations (PSI), where he was the lead investigative attorney concerning abusive debt practices, ineffective oversight of dual use exports and technologies, and oversight of waste, fraud and abuse at the United Nations Development Programme

Credentials

  • The University of Texas School of Law, J.D., with honors, 2003
  • Brown University, B.A., 1999
  • Assistant Chief / Trial Attorney, U.S. Department of Justice, Criminal Division, Fraud Section, FCPA Unit, 2014–2019
  • Counsel (DOJ Detailee), U.S. Senate Committee on the Judiciary, 2017
  • Assistant United States Attorney, United States Attorney’s Office for the District of Columbia, 2008–2014
  • Trial Attorney (USAO Detailee), U.S. Department of Justice, Federal Programs Branch – Guantanamo Bay Litigation Team, 2010–2011
  • Counsel, U.S. Senate Permanent Subcommittee on Investigations, 2008
  • Associate, Akin Gump Strauss Hauer & Feld LLP, 2005–2008
  • Associate and Co-Chair of Pro Bono Committee, Strasburger & Price, LLP, 2003–2005
  • Chambers USA, Litigation: White-Collar Crime & Government Investigations (District of Columbia), 2022 and 2023
  • Legal 500 Latin America, Compliance and Investigations, 2021–2024
  • Selected to the 500 Leading Litigators in America, Lawdragon, 2023 and 2024
  • Who’s Who Legal: Investigations (USA), 2021
  • Global Investigations Review (GIR) 100, 2023
  • Global Investigations Review Enforcement Agency/Prosecutor of the Year, 2019
  • Federal Bureau of Investigation Service Award, 2019
  • Homeland Security Investigations’ Outstanding Investigative Accomplishment Award for Financial Crime, 2017
  • Department of Justice Assistant Attorney General’s Award for Exceptional Service, 2016
  • Homeland Security Investigations’ Outstanding Investigative Accomplishment Award for Financial Crime, 2015
  • Multiple DOJ Special Service Awards, 2011–2014
  • Edward B. Williams Washington, D.C. Inn of Court, Barrister (2017–present)
  • Vogel Alcove, Board Member (2023–present)
  • Akiba Yavneh Academy, Board Member (2023–present)
  • The University of Texas School of Law, Alumni Association Executive Committee, D.C. Steering Committee (2014–present)
  • St. Mark’s School of Texas, Alumni Board Member & Chair, D.C. Regional Club (2018–present)
  • U.S. Holocaust Memorial Museum, Lawyers Committee, (2022–present)
  • AUSA Association of Washington, D.C. (2012–present)
  • Jewish Federation of Dallas, Cardozo Society (2022–present)
  • Jewish Federation of Greater Washington (2012–2022)
  • Brown University, Alumni Association & Mentor, Brown Football Association (2010–present)
  • Triangle Cities Pro Bono Legal Clinic at St. Philip’s School, Founder, Director and Recipient of Dallas Bar Association’s 2004 Pro Bono “Special Services Award” (2003–2005)
  • District of Columbia
  • Texas
  • “Victim Rights in FCPA Cases: Opportunities to Seize and Pitfalls to Avoid for Corporate Counsel,” State Bar Litigation Section Report: The Advocate, Fall 2023, Volume 104 (co-author)
  • DOJ’s Updated Guidance on Evaluating Corporate Compliance Programs, Houston Compliance Counsel Exchange Webcast (June 26, 2020) (panelist)
  • Lessons from Recent Compliance Failures, Wall Street Journal/Dow Jones Risk & Compliance Webinar (June 25, 2020) (panelist)
  • Public Corruption Seminar: FCPA 101, The George Washington University Law School, Washington, D.C. (April 2, 2020) (guest lecturer)
  • Refining Corporate Compliance: A Look at Third-Party Risk and Global Sanctions, Dow Jones Breakfast Panel Discussion, Houston, Texas (February 25, 2020) (panelist)
  • ACI’s 14th Annual Forum on the Foreign Corrupt Practices Act, Houston, Texas (January 29-30, 2020) (co-chair and speaker)
  • The FCPA Compliance Report PodcastThe Compliance Evangelist (January 6, 2020) (speaker)
  • INSIGHT: DOJ Looks for More Data in New Corporate Compliance GuidanceBloomberg Law, June 18, 2020 (quoted)
  • The Future of Corporate Compliance: More demanding requirements, enhanced technology, and a sharper focus on the right priorities, Wall Street Journal, March 18, 2019 (quoted)
  • Walmart’s DOJ Deal Evinces New Corporate Monitoring Policy, Law 360, June 24, 2019 (quoted)
  • Departed FCPA prosecutor: Records will be broken this year, Global Investigations Review, June 26, 2019 (quoted)
  • Former DOJ FCPA Unit Associate Chief Joins Vinson & Elkins’ White Collar Practice, Anti-Corruption Report, June 26, 2019 (quoted)
  • FCPA Flash Podcast – A Conversation with Fry Wernick, FCPA Professor, June 28, 2019 (quoted)
  • The FCPA on the rise: bribes, booms and bonuses, Energy Voice, October 16, 2019 (quoted)
  • “How to Defend Your Program to the Agencies: Practitioners Discuss Their Experiences Amid the Latest DOJ Guidance and Increased Global Enforcement,” 36th International Conference on the Foreign Corrupt Practices Act, December 4, 2019 (panelist)
  • Recent Trends and Investigations in FCPA Enforcement, Linworld Asia Anti-Corruption Compliance Summit 2019, Singapore (December 2, 2019) (speaker)
  • FCPA Enforcement Trends Impacting the Energy Industry, Vinson & Elkins Energy Series, Houston, Texas (October 17, 2019) (speaker)
  • The Foreign Corrupt Practices Act: An Inside Look at Enforcement and Why It Matters to You and Your Clients, Dallas Bar Association CLE Clinic at Belo Mansion, Dallas, Texas (September 20, 2019) (speaker)
  • FCPA Issues and Developments, UT Law CLE’s 6th Annual Government Enforcement Institute, Houston, Texas (September 12, 2019) (panelist)
  • FCPA Flash Podcast, FCPA Professor (June 28, 2019) (speaker)
  • Government Compliance Roundtable: Examining the Convergence of ABAC-International Trade and the Current Priorities and Targets for Enforcement, Cooperation, Coordinated Investigations and Voluntary Disclosure, A.C.E.S. Compliance Summit, Washington, D.C. (April 16, 2019) (panelist)
  • The Future of Corporate Compliance, Dow Jones / Wall Street Journal Breakfast Briefing, New York, New York (March 12, 2019) (keynote interview)
  • Is Mexico Moving Toward a Level Playing Field?  Compliance & Anti-Corruption Framework in Local and Cross-Border Business, United States-Mexico Chamber of Commerce, New York, New York (February 28, 2019) (panelist)
  • Controlling Third Party Corruption: A Conversation with FCPA Regulators, Aravo Solutions Webinar, Washington, D.C. (February 27, 2019) (panelist)
  • Private Sector and Law Enforcement: Constructive Engagement to Counter Corruption, International Centre for Collective Action – Anti-Corruption Collective Action: Evolution to Revolution, Basel, Switzerland (November 14, 2018) (panelist)
  • Pre-Trial Resolutions on Three Continents: Experiences in Brazil, Canada, Chile, the Netherlands, and the U.S., DOJ/SEC/FBI Foreign Bribery and Corruption Conference, Washington, D.C. (November 7, 2018) (speaker and panelist)
  • Effects of US v. Microsoft and CLOUD Act on FCPA Investigations and Enforcement, Federal Bureau of Investigation International Corruption Unit In-Service Training, Seattle, Washington (August 30, 2018) (speaker)
  • Case Study on Telecommunications Across the CIS: Lessons on Risks with the Selection of Local Partners, ACI’s 9th Global Forum on Anti-Corruption Compliance in High-Risk Markets, Washington, D.C. (July 25, 2018) (speaker and panelist)
  • International Corruption and the FCPA, Defense Criminal Investigative Service – International Fraud Working Group Meeting, Garmisch-Partenkirchen, Germany (June 26-28, 2018) (panelist)
  • FCPA Investigations, U.S. Attorney’s Office for Western District of Texas – Training of AUSAs, San Antonio, Texas (June 5, 2018) (speaker)
  • FCPA Investigations, U.S. Attorney’s Office for Northern District of Texas – Training of AUSAs, Dallas, Texas (May 16, 2018) (speaker)
  • Organization for Economic Co-operation and Development (OECD) Working Group on Bribery Plenary Meeting, Paris, France (March 13-16, 2018) (United States delegate)
  • Corporate Compliance and FCPA Enforcement, 2018 Fair Player Club Summit & Pledge Ceremony, Seoul, South Korea (March 7, 2018) (speaker and panelist)
  • Internal Investigation Simulation: Evaluating Corporate Corruption, Georgetown University Law Center, Washington, D.C. (January 11, 2018) (guest lecturer)
  • Negotiations on Anti-Corruption Provisions of North American Free Trade Agreement (NAFTA), Multilateral Negotiations with U.S., Mexico and Canada, Washington, D.C. (December 11, 2017) (United States delegate)
  • U.S. FCPA Investigations, Office of Overseas Prosecutorial Development – Presentation to Uzbek Delegation, Washington, D.C. (December 5, 2017) (speaker and panelist)
  • United Nations Convention Against Corruption, Conference of State Parties, Vienna, Austria (November 6-10, 2017) (United States delegate and negotiator)
  • Developing Evidence: Techniques and Tips to Aggressively and Efficiently Advance an Investigation, Fraud Section All Attorney Training, Washington, D.C. (October 26, 2017) (speaker and panelist)
  • Obtaining Evidence Domestically and Abroad, Fraud Section FCPA Unit Training, Washington, D.C. (September 13, 2017) (speaker and panelist)
  • International Law, Human Rights & Fighting Impunity: Fighting War Crimes & Economic Crimes, Georgetown University Law Center, Washington, D.C. (March 28, 2017) (guest lecturer)
  • Internal Investigation Simulation: Evaluating Corruption in Corporate Transactions, Georgetown University Law Center, Washington, D.C. (January 12, 2017) (guest lecturer)
  • United Nations General Assembly, Second Committee on Macroeconomic Policy Questions Concerning Promotion of International Cooperation to Curb and Recover Illicit Financial Flows, United Nations, New York, N.Y. (November 16, 2016) (United States negotiator and subject matter expert on Corruption and Asset Forfeiture)
  • VimpelCom Case Study, DOJ/SEC/FBI Foreign Bribery and Corruption Conference, Washington, D.C. (November 2, 2016) (speaker and panelist)
  • Break-Out Session with Foreign Prosecutors on Hypothetical Bribery Case, DOJ/FBI/SEC Foreign Bribery and Corruption Conference, Washington, D.C. (November 1, 2016) (trainer)
  • United Nations Convention Against Corruption, Asset Recovery Working Group, Vienna, Austria (August 25-26, 2016) (United States delegate, panelist, and subject matter expert on Corruption and Asset Forfeiture)
  • International Keynote Q&A: Department of Justice Address, Australian Financial Crime Summit, Sydney, Australia (August 16, 2016) (keynote speaker)
  • Trials and Corporate Resolutions, Fraud Section Training, Washington, D.C. (April 28, 2016) (speaker and panelist)
  • U.S. FCPA Investigations, Office of Overseas Prosecutorial Development – International Visitors Leadership Program, Washington, D.C. (February 24, 2016) (speaker)
  • Investigative Techniques, Fraud Section Training, Washington, D.C. (January 12, 2016) (speaker)
  • Cross-Examination, Fraud Section Annual Training, Washington, D.C. (October 15, 2015) (speaker and panelist)
  • Investigative Techniques, Fraud Section Annual Training, Washington, D.C. (October 14, 2015) (speaker and panelist)
  • Prosecuting Fraud and Corruption, American University Washington College of Law, Washington, D.C. (November 12, 2014) (guest speaker)
  • Cross-Examination of Expert Witnesses, U.S. Attorney’s Office Training, Washington, D.C. (2010) (speaker)
  • Basic Trial Advocacy, U.S. Attorney’s Office Training for New AUSAs, Washington, D.C. (2009) (speaker)
  • Congress’ Power to Investigate and Punish for Contempt: The Congressional Subpoena – Enforceability and Consequences, The 22nd Annual ABA Conference on White Collar Crime, Materials for the Program on Congressional Investigations, Miami, Florida (March 2008) (author, with Michael J. Madigan)
  • Mold: One Year Later; Insurance & Governmental Developments, Defense Research Institute: For the Defense, Dallas, Texas (August 2002) (Contributor, with W. Edward Carlton)