Verified profile

Diana R. Shaw

Partner, White Collar & Government Investigations

Diana R. Shaw's profile photo
LocationWashingtonUnited States
Current rolePartnerWiley Rein LLP · since Apr 2024
Government service8yrsU.S. Department of State(DOS) · U.S. Department of Homeland Security (DHS)

About

Diana joined Wiley after a distinguished career in government, most recently serving as the Acting Inspector General of the U.S. Department of State. With deep expertise in investigations, good governance, risk management, and compliance, she brings unparalleled insight to clients navigating complex challenges involving legal, political, and reputational risks.

During her time at the Department of State, Diana led the Office of Inspector General’s criminal and civil investigative programs, overseeing high-profile domestic and cross-border investigations into allegations of bid-rigging, bribery, kickbacks, and fraud involving large U.S. and multi-national corporations. She also investigated some of the most senior officials in government for ethics violations and other serious misconduct. She also has extensive experience auditing government programs and contracts to identify and remediate potential fraud, waste, and abuse.

Diana’s investigative expertise also extends to congressional investigations. She has engaged in every stage of the process—from responding to targeted information requests triggering little public attention to participating in some of the most high-profile and contentious investigations and oversight hearings posing significant legal, political, and reputational risks.

A strong advocate for robust compliance programs, Diana understands the critical role they play in mitigating risk. She is highly knowledgeable about international governance standards and key compliance areas, including compliance with the Foreign Corrupt Practices Act, U.K. Bribery Act, and anti-money laundering and securities laws. She conducts risk and compliance program assessments, helping clients across industries develop and/or enhance their compliance frameworks.

Drawing on her experience conducting risk and compliance program assessments, Diana advises clients on matters involving institutional culture and social responsibility and helps clients develop tailored ESG strategies, policies, and guidelines. Her portfolio covers a wide range of issues, including supply chain diligence, sustainability, social impact, and human rights. She has developed and led programs to improve organizational culture, workplace inclusion, and employee engagement, while also advising clients navigating the shifting DEI policy and legal landscape as they look to balance business objectives, values, and risk appetite. Diana also has significant experience conducting and resolving sensitive workplace investigations involving allegations of employee misconduct, harassment, discrimination, and/or retaliation.

Roles

Apr 2024–Present
Current role

Partner

Wiley Rein LLP

Washington, District of Columbia

Foreign Corrupt Practices Act (FCPA)Civil LitigationCriminal DefenseWhite Collar CrimeComplianceRisk ManagerLitigation Support SpecialistCriminal LawEnvironmental, Social, and Governance (ESG)Appellate LitigationCriminal InvestigationEmployment / Labor Law
Dec 2020–Apr 2024
Former role

Acting Inspector General

U.S. Department of State(DOS)

District of Columbia

Federal GovernmentComplianceCriminal Investigation

May 2020–Dec 2020
Former role

Deputy Inspector General

U.S. Department of State(DOS)

District of Columbia

AuditingFederal GovernmentLegal InvestigatorGovernment ContractsComplianceGovernmentLegalChief Operating OfficerBudgeting and Budget AnalysisCriminal Investigation

Apr 2019–May 2020
Former role

Assistant Inspector General for Special Reviews & Evaluations

U.S. Department of Homeland Security (DHS), Office of Inspector General

(appointed)District of Columbia

Legal InvestigatorCompliance

Mar 2018–Mar 2019
Former role

Counsel to the Inspector General

U.S. Department of Homeland Security (DHS)

(appointed)District of Columbia

Legal InvestigatorCompliance

Sep 2017–Mar 2018
Former role

Director, Special Reviews Group

U.S. Department of Homeland Security (DHS)

(appointed)District of Columbia

Compliance

Feb 2017–May 2017
Former role

Acting Director of External Affairs

U.S. Department of Homeland Security (DHS), Office of the Inspector General

(appointed)District of Columbia

InvestigationsLegal Investigator

Jul 2016–Sep 2017
Former role

Assistant Counsel to the Inspector General

U.S. Department of Homeland Security (DHS)

(appointed)District of Columbia

Compliance

Sep 2007–Jul 2016
Former role

Counsel

O'Melveny & Myers LLP

Washington, District of Columbia

Corporate CounselLegal Officers and PractitionersAccount ManagerLegalCriminal Investigation

Representative matters

Litigation and Investigations

May 2025

Investigated numerous large companies for alleged fraud, bid-rigging, and other wrongdoing related to corporate use of federal aid and/or participation in government programs. Spearheaded the effort to provide whole-of-government oversight of the $113 billion U.S. government response to the situation in Ukraine. Testified at multiple congressional oversight hearings on issues and investigations relating to government programs. Managed public relations challenges associated with congressional inquiries/investigations; advised Presidentially appointed nominees through the Senate confirmation process. Designed and executed a time-sensitive investigation of a prominent university’s handling of allegations of sexual assault that were first reported, and later retracted, by a U.S. media outlet. Led sensitive investigation of alleged ethics violations involving university general counsel. Helped obtain a $110 million settlement for a corporate client in a suit against former investors. Helped negotiate settlement of a government enforcement action for one-fifth the proposed fine amount (related to allegations of price-fixing by a non-U.S. airline).

Compliance

May 2025

Advised defense company through State Department compliance inquiry for alleged ITAR violations. Set up a compliance program (from the ground up) for a foreign company following its acquisition by a large U.S. financial services firm. Regularly assisted clients with enhancing compliance programs, including developing and strengthening standards of conduct, anti-bribery and corruption policies and procedures, and third-party due diligence policies and procedures. Created and customized trainings for clients on industry-specific regulations and related compliance risks.

Advising and Counseling

May 2025

Designed OIG engagement strategy for telecommunications company involved in multiple OIG audits. Advised large federal assistance award recipient on compliance with Trump Administration executive orders related to DEI, including potential False Claims Act exposure. Advised on all forms of congressional engagement, including how to engage with committee staff, responding to written inquiries, preparing to testify in a congressional hearing or sit for a congressional interview, and conducting outreach/engagement with individual Senators and Representatives. Assessed compliance with cybersecurity laws, regulations, and implementing policies; conducted cybersecurity risk assessments, including identifying system vulnerabilities; implemented cybersecurity safeguards and improved overall system efficiencies; investigated and remediated cybersecurity breaches. Advised on privacy matters, including matters involving U.S. or European Union privacy laws; assessed compliance with applicable privacy and data protection policies, laws, and regulations; implemented systemic privacy safeguards and internal controls; investigated and remediated privacy breaches. Assessed compliance with immigration policy, laws, and regulations; advised on asylum law and civil rights and civil liberties issues; evaluated the extent to which current and/or proposed immigration policies advanced policy goals and objectives.

Recognition

Honors

Recognized more than 20 times by the Council of the Inspectors General on Integrity and Efficiency (CIGIE)

Acting Inspector General for the State Department

May 2024

During her tenure as the Acting Inspector General for the State Department (2020-2024), Diana’s office was recognized more than 20 times by the Council of the Inspectors General on Integrity and Efficiency (CIGIE) for excellence in auditing, investigation, and inspecting.

2019 CIGIE Excellence Award

CIGIE

January 2019

Received the 2019 CIGIE Excellence Award for overseeing the special review of family separation issues under the Trump Administration’s Zero Tolerance Policy.

2017 Inspector General Award

Inspector General

January 2017

Received the 2017 Inspector General Award for preparing the DHS Inspector General to testify at six congressional hearings within a six-week period.

Publications & speeches

“Illegal DEI”: Key Considerations for Higher Education and the Private Sector in the New Administration

Wiley.law

May 2025

On January 21, 2025, President Trump issued Executive Order (EO) 14173, titled “Ending Illegal Discrimination and Restoring Merit-Based Opportunity.” The EO raises significant new considerations for private companies and institutions of higher education that operate in the United States regarding their diversity, equity, inclusion, and accessibility (DEI or DEIA) programs because it directs all federal agencies, including the U.S. Department of Education (DOE), to “terminate all discriminatory and illegal preferences, mandates, policies, programs, activities, guidance, regulations, enforcement actions, consent orders, and requirements” and “enforce [the country’s] longstanding civil rights laws and to combat illegal private-sector DEI preferences, mandates, policies, programs, and activities.” The EO does not define what constitutes an “illegal DEI preference or program,” which has led to uncertainty about its scope.

Link

https://www.wiley.law/wicked-coin-podcast#OilandOpulence

Reuters

April 2025

The news over the past few weeks has been saturated with reports describing efforts by the new Administration to rein in federal spending and shrink the bureaucracy. These efforts are having a downstream impact on federal contractors, many of whose contracts with the government are being terminated and/or scrutinized to assess alignment with the Administration's priorities.

Link

Fourth Circuit Stays Preliminary Injunction of DEI-Focused Executive Order Provisions

Wiley.law

March 2025

WHAT: The U.S. Court of Appeals panel has stayed a preliminary injunction that the U.S. District Court for the District of Maryland had issued covering parts of two Executive Orders: EO 14151, “Ending Radical and Wasteful Government DEI Programs and Preferencing,” and EO 14173, “Ending Illegal Discrimination and Restoring Merit-Based Opportunity.” The Executive Orders (collectively, the DEI EOs) seek to discourage and eliminate Diversity, Equity, and Inclusion (DEI) concepts, policies, and practices across the federal government and “encourage” the private sector to terminate DEI programs that constitute illegal discrimination and preferences.

Link

Key Parts of Anti-DEI Executive Orders Blocked by Federal Judge

Wiley.law

February 2025

UPDATE as of March 5, 2025: Within days of our initial publication of this alert, additional lawsuits with identical or similar claims were filed challenging the DEI EOs. On February 20, the San Francisco AIDS Foundation filed a complaint in the District Court for the Northern District of California San Francisco Division asserting that the DEI EOs and EO 14168, “Defending Women From Gender Ideology Extremism and Restoring Biological Truth to the Federal Government,” violate the First and Fifth Amendments and are ultra vires presidential action in excess of authority.

Link

Impacts of New DEI Executive Order Extend Beyond Federal Government to Private Sector

Wiley.law

January 2025

*UPDATE: On February 5, 2025, Attorney General Pam Bondi issued a memorandum on the DOJ's priorities to effectuate Executive Order 14173, "Ending Illegal Discrimination and Restoring Merit Based Opportunity", which is discussed in greater detail here.

Link

Bracing for Impact: Health Care in the Crosshairs Under the New Administration’s Enforcement Agenda

Wiley — Webinar

With the health care industry increasingly in the government’s crosshairs, this webinar unpacks evolving enforcement priorities under the new Administration – from False Claims Act crackdowns to expanded oversight – and explores the strategies organizations need to be developing and implementing now to mitigate the new and heightened risks posed by the intensifying enforcement landscape.

Link

Campus Protests: Navigating the Legal, Political, and Reputational Risks

SCCE Higher Education Compliance Conference — Orlando, FL

Link

Dictator Deluxe: Chechnya's Eccentric Strongman

Wiley.law — PODCAST

May 2025

Join hosts Diana Shaw and Tatiana Sainati as they explore the captivating and controversial life of the current head of the Chechen Republic. In this episode, they unpack one man's rise to power, including his opulent lifestyle and the dark underbelly of his regime. From lavish palaces and exotic pets to allegations of human rights abuses and corruption, this episode uncovers the many facets of a leader who is equal parts bling, violence, nationalism, and religion. Discover how this cult of personality has shaped Chechnya and the implications for its future.

Link

Critical Issues in Higher Education: Title VI, Free Speech, Foreign Funding, and More

Wiley — Webinar

May 2025

This webinar will dive into recent actions by the Trump Administration and the emerging risks faced by universities and research institutions. Panelists will focus on the implications of key legal and policy shifts, as well as analyze recent Executive Orders and agency actions related to critical issues such as Title VI compliance, free speech, foreign funding, and export controls and sanctions. Practical strategies for managing the risks associated with these issues – including balancing stakeholder interests, legal obligations, First Amendment rights, and campus safety concerns – will be discussed.

Link

Oil, Opulence, and One Crystal-Encrusted Michael Jackson Glove

Wiley.law — PODCAST

April 2025

Join hosts Tatiana Sainati and Diana Shaw as they delve into the harrowing history of corruption and violence in the Republic of Equatorial Guinea. Discover how a single political family managed to siphon off the nation's vast oil wealth and amass an astonishing portfolio of assets, including 11 luxury sports cars, lavish mansion estates, and a collection of Michael Jackson memorabilia. Tune in to learn about the international efforts to hold these kleptocrats accountable.

Link