Christopher C. Caffarone

-During his 15 years as an AUSA, Chris investigated, prosecuted and supervised cases, including complex white collar criminal matters. -He spent five years at an AmLaw 100 firm representing corporate clients in commercial disputes and complex federal and state civil actions, primarily in the area of securities litigation. -As an auditor, Chris planned, coordinated and administrated the day-to-day execution of audit engagements, reviewed Fortune 500 companies’ annual and interim financial statements and related disclosures, and prepared reports evaluating companies’ internal controls.

-During an eight-month trial, convicted CEO and COO of a publicly traded company for a complex $200 million accounting fraud, securities fraud and insider trading (U.S. v. Brooks). -Led investigation and successful prosecution of seven defendants, including after a six-week trial, for their roles in a $400 million securities fraud (U.S. v. Ciccone). -Tried the highest-ranking public official in Nassau County and his spouse for bribery and obstruction of justice (U.S. v. Mangano). -Led investigation and prosecution of defendant for engaging in a $60 million Ponzi scheme (U.S. v. Barkany). -Prosecuted real estate mogul and investment fund manager for securities fraud for engaging in a $100 million investment scheme (U.S. v. Callahan). -Led investigation and prosecution of business owner and tax preparer, who was an attorney and former IRS revenue agent, for $30 million tax evasion (U.S. v. Kornblatt). -Led investigation and successful prosecution of an investment advisor for securities fraud in connection with a multimillion-dollar investment scheme (U.S. v. Perera). -Led investigation and prosecution of 10 defendants, including an NYPD detective, responsible for more than 45 commercial and residential burglaries, stealing approximately $10 million in cash and property (U.S. v. Arias). -Prosecuted 15 members and associates of the Pagan’s Outlaw Motorcycle Gang for racketeering, attempted murder and weapons offenses (U.S. v. Ebeling). -Conducted numerous racketeering trials involving murder, rape, sex trafficking, witness tampering, robbery and narcotics trafficking (U.S. v. Lewis, U.S. v. Davis, U.S. v. Osborne, and U.S. v. Smith). -As the acting chief of the Business and Securities Fraud section, supervised 13 attorneys responsible for prosecuting complex frauds, including the trial of senior executives of a hedge fund with more than $1 billion in assets under management responsible for operating a scheme to defraud bondholders of an energy company (U.S. v. Nordlicht). -As the co-coordinator of the Transational Elder Fraud Strike Force, conducted community outreach and investigated individuals committing frauds against the elderly. -As the deputy chief of the Long Island Criminal Division, supervised an office that serviced a population of 2.8 million people, led 17 prosecutors, and coordinated with numerous federal agencies and more than 30 local police departments. Supervised more than a hundred cases, including a $700 million health care fraud case (U.S. v. James).

On May 22, 2025, the U.S. Supreme Court decided Kousisis et al. v. United States, settling a Circuit split as to whether a federal fraud conviction can stand even if the defendant did not intend to cause the victim economic loss. In a decision written by Justice Amy Coney Barrett, with Justices Gorsuch, Thomas and Sotomayor authoring separate concurrences, the Court held it can.

On February 10, 2025, President Donald Trump signed an Executive Order directing the Department of Justice (DOJ) to pause enforcement of the U.S. Foreign Corrupt Practices Act (FCPA), citing concerns over the competitive disadvantage that it imposes on U.S. businesses. Just days earlier, Attorney General Pam Bondi issued a memorandum signaling a narrowing of DOJ enforcement priorities with respect to the FCPA and Foreign Agents Registration Act (FARA). This alert provides an overview of the current state of FCPA and FARA enforcement, discussing the compliance implications of new DOJ policy for companies engaged in cross-border trade.

On December 3, 2024, the U.S. District Court for the Eastern District of Texas (Mazzant, J.) granted a preliminary injunction in Texas Top Cop Shop, Inc., et al. v. Merrick Garland, Attorney General of the United States, et al., No. 4:24-CV-478 (E.D. Tex. filed Dec. 3, 2024) (the “Order”) enjoining enforcement of the Corporate Transparency Act, 31 U.S.C. § 5336 (CTA) and the Reporting Rule, 31 C.F.R. 1010.380. The court also stayed the January 1, 2025 compliance deadline for reporting companies—as defined by 31 U.S.C. § 5336(b)—to file beneficial ownership information reports under § 5336(b)(2). Order at 78-79. The scope of the injunction is nationwide. Id. at 2, 77-78.