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Michael W. Ward
Michael W. Ward
Partner — Government Investigations & White Collar Criminal Defense
Partner — Government Investigations & White Collar Criminal Defense

Michael W. Ward

Michael W. Ward
San Francisco

555 Mission Street
Suite 2000
San Francisco, CA 94105

Our clients work hard to create value for their shareholders and create jobs for their employees. Government investigations of perceived or unintended violations of the law can very quickly destroy that value. I apply my unique background as both a former prosecutor and an in-house compliance officer to help senior executives and Boards protect that value.
Michael W. Ward

Mike has built his practice around advising and defending companies, which often involves efficiently targeting the wrongdoing at its core and eliminating government misperceptions. He has deep experience implementing best practices in corporate compliance programs to demonstrate companies’ commitments to meeting their obligations.

Mike has a rare background combining deep trial experience as a federal prosecutor and a business orientation acquired as an in-house chief compliance officer in multiple companies and industries. He joins V&E after serving as a chief risk and compliance officer for a Silicon Valley-based networking equipment company. There, he led a worldwide ethics and compliance program, enterprise risk management program and various legal and legal operations teams. He also oversaw a six-year Foreign Corrupt Practices Act investigation spanning multiple countries, including Russia and China, and his efforts resulted in a declination from the U.S. Department of Justice and a non-bribery civil resolution with the Securities & Exchange Commission.

Mike’s career began in private practice, followed by serving nearly 16 years as an Assistant United States Attorney for the U.S. Department of Justice in Minneapolis. In this role, Ward led numerous federal criminal investigations, tried over 50 federal criminal jury trials, and regularly assessed the effectiveness of corporate compliance programs. He oversaw the investigation and prosecution of all categories of federal crimes, including public corruption, insider trading, money laundering, terrorist financing, bank fraud, currency transaction structuring, price fixing, government contracting frauds and export control violations. In recognition of his contributions, Mike was recognized with the National Director’s Award for Outstanding Performance.

Company Defense and Counseling

  • (US, China, Russia, India, other) — Coordinated internal investigation and defense of technology company to FCPA investigation of customer travel and entertainment practices and channel partner discount manipulation allegations resulting in declination from US DOJ and civil non-bribery settlement with SEC

  • Designed and implemented compliance programs and as CCO oversaw all worldwide internal investigations for companies in technology sector (hardware and software), healthcare and pharma distribution, and retail

  • Retained by Board and CCO of multi-national security services company and government contractor to conduct comprehensive compliance program assessment and substantive risk assessment

  • Retained by General Counsel to perform proactive anti-corruption risk assessment for multi-national food production and distribution company

  • Conducted proactive anti-corruption risk assessment on behalf of a Fortune 100 financial services organization

  • (Taiwan) — Defended technology company in competition law investigation of company’s channel partner deal registration platform

  • Designed and implemented scalable third-party due diligence programs for technology companies, healthcare distribution and multi-national retail company

  • Implemented practical, risk based and scalable third-party gift, travel and entertainment compliance policies and procedures

  • Implemented compliance risk data analytics programs and discount and other transaction due diligence procedures to proactively identify compliance risk

  • (D. Minn.) — Lead prosecutor in investigation and conviction at trial of Minneapolis real estate developer for bribery of elected city officials; including prevailing in challenges to the constitutionality of the federal statute at issue culminating in a 9-0 ruling by the United States Supreme Court

  • (D. Minn.) — Lead prosecutor in an extended undercover investigation of Minneapolis city government obtained conviction of Minneapolis City Council Member on extortion charges; the investigation also led to the conviction of a second city council member

  • (D. Minn.) — Co-lead prosecutor in the first ever prosecution and conviction of a Minnesota state senator; the case arising out of that senator/attorney’s operation of a “self-insurance” scheme which defrauded an Indian Tribe; this case also involved the conviction of the Chairman and Secretary-Treasurer of the Leech Lake Band of Chippewa Indians in a precedent-setting case affecting tribal sovereign immunity

  • (D. Minn. 1999) — Lead prosecutor in the subsequent prosecution of the succeeding Secretary-Treasurer and other high-ranking officials of the Leech Lake Band for a “kickback” scheme involving tribal construction projects

  • (D. Minn.) — Lead prosecutor in the conviction of the Chief Deputy Sheriff of Carver County, Minnesota on mail fraud, theft and tax charges arising out of a fraudulent charitable donation and embezzlement scheme

  • (D. Minn.) — Lead prosecutor in conviction at trial of two officials of the Minneapolis Public Housing Authority for their operation of an extortionate bribery scheme to influence the award of low-income public housing units to eligible applicants in exchange for cash bribes

  • (D. Minn.) — Lead prosecutor in conviction of a U.S. Veterans Affairs contracting official and several construction contractors for their participation in a bribery scheme that influenced the award of minority contract set asides for a series of large federal construction projects at the Minneapolis VA hospital

  • (D. Minn.) — Lead prosecutor in the conviction at trial on all counts for insider trading and money laundering of a health insurance company corporate vice president who purchased stock options on the basis of material non-public information concerning a proposed acquisition

  • (D.Minn.) — Lead prosecutor in the conviction of multiple construction contractors involved in a felony price fixing scheme intended to allocate federally funded construction contracts for the “sound proofing” by the FAA of thousands of homes adjacent to the Twin Cities International Airport

  • (D. Minn.) — Lead prosecutor in the conviction at trial of the Chairman/CEO and his co-founder of an elder care assisted living facility company on mail fraud offenses related to the fraudulent solicitation of investors

  • (D. Minn.) — Lead prosecutor in the prosecution of Japanese physician and recovery of intellectual property stolen from a research laboratory of the Mayo Clinic

  • (D. Minn.) — Lead prosecutor in the conviction at trial on arson and fraud charges of the owners of a failing St. Paul business seeking to defraud their insurance company

  • (D. Minn.) — Lead prosecutor in successful prosecution of a multi-state “identity theft” credit card fraud conspiracy case

  • (D. Minn.) — Lead prosecutor in the investigation and conviction of perpetrators of a nationwide opal gemstone distribution fraud and multi-million-dollar money laundering scheme

  • (D. Minn.) — Lead prosecutor of a Somali immigrant and Minneapolis resident for conspiring to provide material support to the al Qaeda terrorist organization by traveling to and then attending al Qaeda terrorist training camps in Afghanistan and later providing financial assistance to al Qaeda associates in Pakistan

  • (D. Minn.) — Lead prosecutor of a Lebanese national and Minneapolis resident, who attended and taught in al Qaeda training camps in Afghanistan and fought in jihad both there and in Chechnya, for making false statements concerning his prior associations and assistance to other al Qaeda associates

  • (D. Minn.) — Lead prosecutor in the conviction at trial of an interstate gun trafficking conspiracy involving an armed gun shop robbery and the execution-style double murder of the two store clerks. This prosecution was recognized with the National Director’s Award from Attorney General Janet Reno for outstanding performance as an Assistant United States Attorney

  • (D. Minn.) — Lead prosecutor in the conviction at trial of several gang members responsible for multiple violent bank robberies; this case involved one of the first ever Daubert-admissibility hearings on the reliability of PCR DNA evidence

  • (D. Minn.) — Co-prosecutor in the conviction at trial on threat charges in a “stalking” and threatening letter campaign which escalated into the fire-bombing of two state court judges’ homes by the defendant; This case also resulted in a National Directors Award from the Bureau of Alcohol, Tobacco and Firearms

Credentials

  • Stanford University, Graduate School of Business, SEP Class of 2018
  • George Washington University, J.D., 1985
  • University of Minnesota, B.A., 1982
  • Chief Risk & Compliance Officer and Deputy General Counsel, Juniper Networks, 2015–April 2020
  • Managing Director, Atlas Compliance, 2013–2015
  • Deputy General Counsel & Vice President, Compliance, Cisco Systems, 2012–2013
  • Associate General Counsel & Chief Compliance Officer, Adobe Systems, 2009–2012
  • Associate General Counsel & Director of Ethics & Compliance, McKesson, Inc., 2008–2009
  • Head of Investigations and Compliance, Target, Inc., 2006–2008
  • Assistant United States Attorney, U.S. Attorney’s Office for the District of Minnesota, 1990–2006
  • Associate, Shearman & Sterling, 1986–1990
  • Judicial Clerk to The Honorable Oliver Seth, Chief Judge, U.S. Court of Appeals, 10th Circuit, 1985–1986
  • American Bar Association, White Collar Section
  • California Lawyers Association, Criminal Law Section
  • Instructor, Society of Corporate Compliance & Ethics
  • Board Member: Bay Area Ethics & Compliance Association (BECA)
  • Board Member: High Tech Compliance Group
  • California
  • “Tech Tools Can Help Firms Probe Misconduct During Pandemic, Compliance Veteran Says,” Wall Street Journal, April 27, 2020
  • “Mike Ward: Companies should prepare to be an open book,” Global Investigations Review, April 15, 2020
  • “The Foreign Corrupt Practices Act:
    Recent Developments and DOJ and SEC Priorities,” 32nd Annual ABA National Institute on White Collar Crime, San Diego, California, March 1, 2018 (co-panelist)
  • “Monitor, Audit, and Assess: Explore the Three Lines of Compliance Defense,” Practicing Law Institute, New York, NY, July 29, 2019 (speaker)
  • “Ensuring Consistency and Objectivity in Compliance Risk Assessments, PLI Institute, San Francisco, CA, November 2016 (speaker)
  • “Conducting an Effective Anti-Bribery Risk Assessment,” TRACE Anti-Bribery Specialist Accreditation (TASA) course, April 29, 2015 (speaker)
  • “The Company You Keep: How to Minimize Minority and Majority Joint Venture Compliance Risks” TRACE Forum, Washington, DC, March 25, 2015 (speaker)
  • “Measuring the Effectiveness of Your Ethics & Compliance Program,” SCCE Compliance & Ethics Institute, Chicago, Illinois, September 15, 2014 (speaker)
  • “FCPA Enforcement Update:
    The Real Enforcement Risks and the Practical Compliance Responses,” Silicon Valley General Counsel All Hands, May 13, 2014 (speaker)
  • “Ensuring Consistency and Objectivity in Compliance Risk Assessments,” PLI Advanced Compliance Institute, San Francisco, CA, November 18, 2013 (speaker)
  • “Ensuring Consistency and Objectivity in Compliance Risk Assessments,” SCCE – Upper West Coast Regional Conference, San Francisco, CA, June 21, 2013 (speaker)
  • “Detecting and Managing Corruption Risks,” Corporate Counsel West, San Francisco, CA, October 31, 2012 (speaker)
  • “How to Detect FCPA Violations at the Bidding and Negotiating Stage,” ACI FCPA Boot Camp, San Francisco, CA, September 27, 2010 (co-panelist)
  • Compliance Risk Assessment Methods and Issues,” SCCE Compliance & Ethics Institute, Chicago, Illinois, September 12, 2010 (speaker)
  • “Top Ten Ways to (Not) Achieve Compliance,” SCCE West Regional Conference, San Francisco, CA, April 2010 (speaker)