Compliance and Investigations
Government, Regulatory, and Compliance

Compliance and Investigations

Leveraging know-how, practicality and experience to give clients well-designed, risk-based and cost-effective compliance solutions.

The attorneys at Culhane understand that one size does not fit all when it comes to compliance programs. We focus on helping each client achieve compliance solutions that are the most effective and appropriate in light of the client’s risk profile, industry, operations, size, culture, regulatory status and budget.

Our partners combine their many years of in-depth regulatory knowledge in a variety of practices areas and industries together with extensive experience working within and for US and global businesses and within the US government to help clients achieve tailored, effective and practical compliance solutions. We have counseled clients on all aspects of compliance, including developing and implementing compliance and ethics programs and training, engaging with internal and external compliance regulators and auditors, administration of compliance programs and assisting with compliance related investigations, examinations, and providing transactional due diligence and advice.

Compliance Programs – development, implementation, and administration. Our partners advise on all aspects of designing, implementing and monitoring compliance and ethics programs, including:

  • Drafting risk-based policies, procedures and practices
  • Working with boards, management and employees to ensure compliance programs are well-designed and effective
  • Providing compliance training and training materials
  • Evaluating and refining procedures for detection of compliance violations
  • Working with boards and senior management to develop and implement thoughtful ethics programs grounded in the client’s culture, mission and vision, including development and implementation of employee codes of conduct, employee handbooks, ethics codes and whistleblower hotlines
  • Performing due diligence review regarding potential suppliers and service providers, business partners, transactions, investors, and mergers and acquisitions
  • Educating legal, regulatory, compliance and audit teams, management and boards on compliance obligations
  • Applying business conduct and ethics standards and benchmarks based on the U.S. Department of Justice (DOJ) sentencing guidelines, the Ethics in Government Act, the Hatch Act, and other regulatory guidance to implement effective compliance and whistleblower programs
  • Matters relating to records management, electronic discovery and attorney-client privilege
  • Responding to subpoenas, government inquiries, investigations and enforcement proceedings, and data access requests and complaints from individuals and regulators


Industry knowledge. Culhane represents clients in diverse industries such as information technology, software design and development, due diligence products and services, social media and digital advertising, leading online marketplace and auction websites, transportation and logistics, manufacturing, automotive, real estate and construction, materials handling, robotics, banking and financial services, and communications technology. We counsel government contractors and sub-contractors in federal procurement, day-to-day ethics and compliance management and operations, including restrictions on the use of appropriated funds to influence the government.

Specialized regulatory knowledge. CM has in-depth knowledge of regulatory standards obligations and expectations affecting clients in a variety of specialized areas, including:

  • U.S. and international data privacy and protection/security, including the General Data Protection Regulation (GDPR) and the EU-US Privacy Shield program
  • bribery, collusion, money laundering, fraud, insider trading, sanctions, improper political activity
  • labor and employment, including sexual/workplace harassment and discrimination and providing harassment and discrimination training and seminars;
  • corporate governance and conflicts of interest (including non-profit entities)
  • digital distribution and media
  • advertising and marketing requirements
  • financial regulatory compliance
  • healthcare, including counseling health care services providers on HIPAA compliance matters and related data security and privacy obligations
  • counseling tax-exempt entities on Internal Revenue Service and state attorney general requirements
  • government contracts
  • automotive sales

Our Government, Regulatory and Compliance partners include partners physically based in and admitted to practice in Washington, DC, who have substantial experience in federal agency service including Deputy General Counsel at the White House Office of Drug Policy, Regional Director in two Federal Trade Commissions, Honors Attorney in the General Counsel’s office of the U.S. Postal Service focusing on compliance and government investigations, and Senior Counsel at the U.S. Securities and Exchange Commission.

Representative matters include:

  • Management and day to day operation of Ethics Compliance Program at the White House Office of Drug Policy from 2000-2013.
  • Part of executive leadership team developing and implementing a comprehensive ethics and compliance program for a multi-billion-dollar U.S. company operating in over 80 countries
  • Assisted a foreign government’s permanent mission to the UN in reviewing and restructuring its procurement program to conform to U.S. government contracting best practices.
  • Successfully gaining unique regulatory clearances for multi-national partnership from U.S. financial regulators.
  • Developed and presented training courses on ethical conduct and government contract compliance requirements
  • Assisted in preparing augmented codes of conduct and remedial measures after identifying problem areas
  • Advised leading wireless telecommunications carrier on the development and implementation of an enterprise-wide data privacy and records retention program.
  • Developed a comprehensive employee handbook and compliance manual for a leading automotive dealership group with multi-state operations
  • Outsourced compliance officer support for U.S. affiliate of European bank, including compliance with U.S. anti-money laundering, sanctions, and FCPA.
  • Advice and support to U.S. subsidiary of Japanese global technology group, for U.S. compliance and ethics activities, export control and multi-jurisdiction joint ventures in U.S. and Europe.
  • Advice and counsel regarding White House Office of Drug Policy social and digital media policies and practices.
  • Advocacy on behalf of U.S. based international non-profit association before U.S. Department of Commerce obtaining EU-U.S. and Swiss-U.S. Privacy Shield Certifications.
  • Advocacy on behalf of foreign corporation before U.S. Department of Commerce obtaining waiver of reporting requirement.