Paul specializes in representing public and private companies of all sizes and high-profile individuals in state and federal investigations. He represents clients across various industries, including pharmaceutical, biotechnology, medical device, and financial services. He enjoys a reputation as one of the top white-collar lawyers in the country, recognized for investigating complex international corporate fraud schemes. Paul defends and resolves large, multi-faceted federal and state investigations arising under criminal and civil statutes barring, among other things, the submission of false claims and the provision of remuneration to induce referrals. Many of these cases have arisen as a result of qui tam cases filed by whistleblowers, under federal and state False Claims Acts.
Prior to joining the firm, Paul served in the Department of Justice (DOJ) as a federal prosecutor for more than 25 years, where he was lead counsel in more than 20 jury trials targeting money laundering; sophisticated financial, corporate, and securities fraud; and health care fraud. As principal deputy chief of the DOJ Criminal Division's Fraud Section, he directed and supervised some of the DOJ's most important initiatives and investigations. Paul's corporate fraud prosecutions have included criminal resolutions with PNC, AIG, General Reinsurance, and BP.
At the DOJ, Paul was instrumental in developing and implementing the Fraud Section's robust health care fraud enforcement program, including placing strike force enforcement teams across the country to combat regional health care fraud schemes. Paul also supervised its FCPA Unit, which, during his tenure, saw a dramatic increase in the number of corporate and individual prosecutions as well as a more than ten-fold increase in the assessment of FCPA fines and penalties.
Paul also previously served as chief of the Economic Crime Section at the US Attorney's Office for the Southern District of Florida, where he supervised and prosecuted a number of significant securities, health care, and bankruptcy fraud cases. As chief, Paul assisted with establishing a first-in-the-nation Health Care Fraud Investigation and Storage Facility in Miramar, Florida, which has been instrumental in efficiently attacking the large volume of health care fraud cases in that district. In addition, as a prosecutor and deputy chief in the Narcotics Section, Paul prosecuted many sophisticated drug and money-laundering enterprises, including the seizure of more than a quarter of a billion dollars in traffickers' foreign bank accounts.
Paul has twice been recognized by the attorney general with the DOJ's highest honor. He has been recognized for his work on the prosecution and dismantling of a Colombian-based cartel, resulting in the seizure and subsequent forfeiture of approximately $200 million in cash. He has also been recognized for his work in the conviction of 28 individuals, including trial convictions of five doctors and pharmacists, involved in a multimillion-dollar health care fraud scheme.
From 1984 through 1989, Paul joined the DOJ's Tax Division as a trial attorney.
During law school, he served as managing editor of the New England Law Review. He then served as judicial law clerk to Chief Judge Steven Andrews of the Oakland County Circuit Court in Michigan and to Judge Howard Kirshbaum of the Colorado Supreme Court.
Representative Matters
- Co-led the trial team in the case of United States v. Ronald Ferguson, et al., resulting in the conviction of seven corporate executives from AIG and General Reinsurance for their role in a $500 million reinsurance accounting fraud scheme.
- Led the investigation into a $7 billion Ponzi scheme conducted through a foreign international bank, resulting in multiple fraud, money laundering, and obstruction charges being filed against the principals of that scheme.
- Investigated and supervised the prosecution of the CEO of Qwest Communications, which, in the case of United States v. Joseph P. Nacchio, resulted in his conviction for insider trading of in excess of $50 million in Qwest stock for which he received a sentence of approximately six years.
Recognitions & Awards
- Washington DC Super Lawyers: Criminal Defense: White Collar (2012 – 2013)
- Ethisphere Institute Attorneys Who Matter (2011)
- Attorney General's Award for Fraud Prevention (2006)
- Attorney General’s Award for Distinguished Service (1996)
- Director's Award for Superior Performance (2003)
- Tax Division's Outstanding Attorney Award (1987)
Paul specializes in representing public and private companies of all sizes and high-profile individuals in state and federal investigations. He represents clients across various industries, including pharmaceutical, biotechnology, medical device, and financial services. He enjoys a reputation as one of the top white-collar lawyers in the country, recognized for investigating complex international corporate fraud schemes. Paul defends and resolves large, multi-faceted federal and state investigations arising under criminal and civil statutes barring, among other things, the submission of false claims and the provision of remuneration to induce referrals. Many of these cases have arisen as a result of qui tam cases filed by whistleblowers, under federal and state False Claims Acts.
Prior to joining the firm, Paul served in the Department of Justice (DOJ) as a federal prosecutor for more than 25 years, where he was lead counsel in more than 20 jury trials targeting money laundering; sophisticated financial, corporate, and securities fraud; and health care fraud. As principal deputy chief of the DOJ Criminal Division's Fraud Section, he directed and supervised some of the DOJ's most important initiatives and investigations. Paul's corporate fraud prosecutions have included criminal resolutions with PNC, AIG, General Reinsurance, and BP.
At the DOJ, Paul was instrumental in developing and implementing the Fraud Section's robust health care fraud enforcement program, including placing strike force enforcement teams across the country to combat regional health care fraud schemes. Paul also supervised its FCPA Unit, which, during his tenure, saw a dramatic increase in the number of corporate and individual prosecutions as well as a more than ten-fold increase in the assessment of FCPA fines and penalties.
Paul also previously served as chief of the Economic Crime Section at the US Attorney's Office for the Southern District of Florida, where he supervised and prosecuted a number of significant securities, health care, and bankruptcy fraud cases. As chief, Paul assisted with establishing a first-in-the-nation Health Care Fraud Investigation and Storage Facility in Miramar, Florida, which has been instrumental in efficiently attacking the large volume of health care fraud cases in that district. In addition, as a prosecutor and deputy chief in the Narcotics Section, Paul prosecuted many sophisticated drug and money-laundering enterprises, including the seizure of more than a quarter of a billion dollars in traffickers' foreign bank accounts.
Paul has twice been recognized by the attorney general with the DOJ's highest honor. He has been recognized for his work on the prosecution and dismantling of a Colombian-based cartel, resulting in the seizure and subsequent forfeiture of approximately $200 million in cash. He has also been recognized for his work in the conviction of 28 individuals, including trial convictions of five doctors and pharmacists, involved in a multimillion-dollar health care fraud scheme.
From 1984 through 1989, Paul joined the DOJ's Tax Division as a trial attorney.
During law school, he served as managing editor of the New England Law Review. He then served as judicial law clerk to Chief Judge Steven Andrews of the Oakland County Circuit Court in Michigan and to Judge Howard Kirshbaum of the Colorado Supreme Court.
Representative Matters
- Co-led the trial team in the case of United States v. Ronald Ferguson, et al., resulting in the conviction of seven corporate executives from AIG and General Reinsurance for their role in a $500 million reinsurance accounting fraud scheme.
- Led the investigation into a $7 billion Ponzi scheme conducted through a foreign international bank, resulting in multiple fraud, money laundering, and obstruction charges being filed against the principals of that scheme.
- Investigated and supervised the prosecution of the CEO of Qwest Communications, which, in the case of United States v. Joseph P. Nacchio, resulted in his conviction for insider trading of in excess of $50 million in Qwest stock for which he received a sentence of approximately six years.
Recognitions & Awards
- Washington DC Super Lawyers: Criminal Defense: White Collar (2012 – 2013)
- Ethisphere Institute Attorneys Who Matter (2011)
- Attorney General's Award for Fraud Prevention (2006)
- Attorney General’s Award for Distinguished Service (1996)
- Director's Award for Superior Performance (2003)
- Tax Division's Outstanding Attorney Award (1987)
Publications
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Co-author,
Navigating Business Corruption Risks in Russia, Financier Worldwide ()
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Co-author,
Avoiding the Mourning After: Minimizing FCPA Risk of Pass Through or Successor Liability, Compliance Today ()
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Co-author,
Comprehensive FCPA Guidance Provides a Roadmap for Companies to Reevaluate and Revise Their Compliance Policies, The FCPA Report ()
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Co-author,
DOJ and SEC Issue Highly Anticipated FCPA Guidance, FCPA Advisory ()
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Co-author,
A Tale of Two Companies, Compliance & Ethics Professional ()
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Co-author,
Ratting out the Competition: New DOJ Strategies, Law360 ()
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Co-author,
Positioning Compliance Programs to Defend Against Increased Enforcement When Financial Institution Account Holders Are Implicated in Fraudulent Schemes, Financier Worldwide Magazine ()
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Co-author,
UK Bribery Act: Understanding & Mitigating Risks, Corporate Alert ()
Speaking Engagements
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Speaker,
Corrupt or Compliant? Protecting Your Company and Executives from FCPA Liability in 2013,
Association of Corporate Counsel San Diego Chapter, San Diego, CA
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Speaker,
Dealing with FCPA (and The UK Bribery Act),
Corporate Directors Forum, San Diego, CA
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Speaker,
Exploiting the New US FCPA Guidance to Avoid Trouble and Comply Effectively,
Association of Certified Financial Crime Specialists, Webinar
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Panelist,
Self-reporting: Voluntary…Mandatory…Coerced?,
Seventh Annual National Institute on Securities Fraud,
American Bar Association, New Orleans, LA
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Speaker,
Effective FCPA and Global Anti-Corruption Compliance to Avoid Criminal, Regulatory and Civil Consequences,
ACFCS 2012 International Financial Crime Conference and Exhibition,
Association of Certified Financial Crime Specialists, New York, NY
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Speaker,
Good ‘Legal Order Processing’ to Avoid Going from ‘Witness’ to ‘Target’ When You Get A Subpoena, Summons or Order,
ACFCS 2012 International Financial Crime Conference and Exhibition,
Association of Certified Financial Crime Specialists, New York, NY
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Panelist,
Inside Federal Agencies,
International Association of Defense Counsel Corporate CounselCollege ,
Corporate Counsel College, Chicago, IL
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Panelist,
Defending Against Allegations of Fraud and Abuse under the UK Bribery and Foreign Corrupt Practices Acts,
National Forum on Fraud and Abuse in the Sale and Marketing of Drugs in New York,
American Conference Institute, New York, NY
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Panelist,
Creative Investigative Techniques in White Collar Cases,
2012 White Collar Crime National Institute,
American Bar Association, Miami Beach, FL
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Moderator,
Self Report? Or Roll the Dice?,
National Institute on Securities Fraud,
American Bar Association, New Orleans, LA
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Newly Adopted Dodd-Frank Whistleblower Rules: Practical Tips & Strategies to Address the New Landscape,
Litigation Summit and Exposition,
American Lawyer and Corporate Counsel
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Risk Management in the New Age of Scrutiny: Strategies, Tips and Guidance for In-House Counsel,
Association of Corporate Counsel, Northeast Chapter
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Panelist,
Retail Operations in China: Capturing the Opportunity and Managing the Risk,
Mintz Levin, Webinar
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Panelist,
Newly Adopted Dodd-Frank Whistleblower Rules: Practical Tips & Strategies to Address the New Landscape,
Newly Adopted Dodd-Frank Whistleblower Rules: Practical Tips & Strategies to Address the New Landsca,
Mintz Levin, Webinar
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State vs. Insolvency Office Holders and Creditors Rights: A Collision of Interests,
Offshore Alert Conference
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National Fraud Prevention Efforts,
National Fraud Issues Conference,
Mortgage Bankers Association
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Insider Trading: A Look at Galleon and Other Recent Cases,
ABA National Institute on Securities Fraud
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Prosecuting Corporate Fraud in Today's Global Environment,
Marcus Evans Corporate Fraud and Risk Conference
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Obstruction of Justice and False Statements: Prosecution and Defense Strategies,
ABA National Institute on White Collar Crime
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Privacy and Confidentiality in Banking in a World of Global Transparency,
Anti Money Laundering Compliance Conference (FIBA)
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Ponzi Scheme Panel,
ABA National Institute on Securities Fraud
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Corporate Liability, Governance and Compliance,
Compliance Institute (HCCA)
Newsroom
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Mintz Levin Attorney Paul E. Pelletier to Speak on FCPA to Corporate Directors Forum and San Diego Chapter of Association of Corporate Counsel , ()
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Nine Mintz Levin Members Named Washington, D.C. Super Lawyers and Rising Stars, ()
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Quoted in
Doping Admission Puts Armstrong in Legal Hot Seat, Law360 ()
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Quoted in
Corruption Risks Increasing in China, Russia, and Mexico, Compliance Week ()
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Quoted in
Inside FCPA Guidance: What to Expect Next, Compliance Week ()
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Quoted in
Justice Department Ends DPA Early, Citing Robust Compliance, Compliance Week ()
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Quoted in
DOJ and SEC’s New FCPA Guidance Provides a Desktop Compliance Reference for Companies, Corporate Counsel ()
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Quoted in
FCPA Still an Enigma after New Guidance, Attys Say, Law360 ()
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Quoted in
Justice Dept. Issues Guidance on Overseas Bribes, New York TImes ()
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Quoted in
The Guidance: The FCPA Bar Reacts, Wall Street Journal ()
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Quoted in
FCPA Enforcement Will Stay Robust beyond Obama’s Second Term, Law360 ()
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Quoted in
Meningitis Suits Stand to Benefit from FDA Criminal Probe, Law360 ()
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Quoted in
Legal Perspective on EHR Meaningful Use Fraud, EHR Intelligence ()
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Quoted in
UK Bribery Act Guidance Sheds Little Light on FCPA, Law360 ()
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Quoted in
Low Hopes for FCPA Guidance, Wall Street Journal ()
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Quoted in
UK Bribery Act Crippled by Lack of Funding, Attys Say, Law360 ()
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Quoted in
The Politics of Fraud, Modern Healthcare ()
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Five Mintz Levin Members Named Washington, D.C. Super Lawyers, ()
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Quoted in
With Wal-Mart Claims, Greater Attention on a Law, New York Times ()
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Quoted in
Wal-Mart Bribery Probe Seen as Examining Coverup Claims, Bloomberg ()
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Quoted in
Wal-Mart May Face FCPA Charges Over Mexican Bribery Plot, Law360 ()
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Quoted in
Allen Stanford Convicted in $7 Billion Investment Fraud, BusinessWeek ()
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Quoted in
Jury Rules Stanford Must Forfeit $330M, Financial Times ()
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Mintz Levin, King &Wood PRC and AMM Consulting Host Webinar on Establishing or Expanding Retail Operations in China, ()
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Quoted in
Man Charged With 'Using' Treasury Secretary's Account to Pay Off Mortgage, FoxNews.com ()
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Mintz Levin Attorney Paul Pelletier Named One of 2011 Attorneys Who Matter by Ethisphere Institute, ()
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Quoted in
UK Expected to Come Down Hard with New Bribery Law, Law360 ()
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Quoted in
Lindsey FCPA Verdicts Prompt Hard Look at Trial Risks, Law360 ()
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Quoted in
High-Ranking DOJ Fraud Cop Heads to Mintz Levin, Law360 ()
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Mintz Levin Adds Former Senior DOJ Fraud Attorney, Paul Pelletier, To Washington, D.C. Office, ()
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Quoted in
Stanford Prosecutor Headed to Mintz Levin, WSJ Blogs: Corruption Currents ()