Jerome Tomas

• Represented the special committee of a publicly traded consumer products company in conducting an internal investigation and SEC and DOJ investigations into potential FCPA violations in China. • Represented a non-US, formerly publicly traded commodities company, in an SEC investigation into its restated financial statements. • Represented a multinational US-based consumer products company in connection with SEC and DOJ investigations into potential violations of US federal securities laws in India, including the FCPA. • Represented a multinational US-based beverages company in connection with SEC and DOJ investigations into potential violations of the US federal securities laws in India, including the FCPA. • Represented a multinational telecommunications company in an investigation related to potential data breaches in several jurisdictions. • Represented a US-based publicly traded company in an internal investigation into the reclassification of expenses and adjustment of reserves in connection with the close of the financial year. • Represented a foreign private issuer in a technology company investigated by the SEC and DOJ for potential FCPA violations in China. Resulted in a declination of enforcement action. • Represented a non-US-based logistics company investigated by the SEC and DOJ for potential FCPA violations in multiple jurisdictions. Acted as lead counsel in resolution of SEC enforcement action, resulting in a settlement on favorable terms. • Represented a US-based public company in connection with an SEC investigation involving potential financial disclosure fraud. • Represented a non-US financial institution investigated by the SEC for potential violations of US federal securities laws. Resolved SEC enforcement action on favorable terms. • Represented a multinational investment bank and securities firm in connection with responding to requests from US securities regulators. • Represented the audit committee of China-based company listed in the US, investigated by SEC and DOJ for potential violations of US federal securities laws. • Represented a China-based company listed in the US investigated by SEC for potential violations of the US federal securities laws.

• Represented the former president for North America of an international pharmaceutical regarding a grand jury investigation by a US Attorney's Office into the company's marketing and advertising practices. • Represented a US-based defense company employee and other service provider employees in connection with SEC and DOJ investigations into potential FCPA violations in China. Matter was ultimately resolved without action taken against the company or the employees. • Represented several finance department employees of a publicly-traded pharmaceutical company in connection with an SEC and derivative investigation arising out of a restatement. • Numerous representations of individuals investigated by the SEC and/or the SEC for insider trading, resulting in a declination of action by the SEC or Finra. • Represented an individual in an SEC investigation and derivative action related to potentially improper payment of real estate management and other fees. • Represented an individual in connection with an SEC investigation into potential auditor independence rule violations, resulting in a declination of action. • Represented the chief compliance officer of a US-based money manager in connection with DOJ, SEC and CFTC investigations of the money manager, resulting in a declination of action. • Represented a former employee of a multinational investment bank in an investigation by several states' Attorneys General into potential fraud in connection with the sale of mortgage-backed securities, as well as a federal law enforcement investigation. • Represented a former senior executive of a US multinational in connection with an SEC and DOJ investigation, including preparing a Wells Submission and negotiating a resolution of the investigation. • Acted as counsel to a non-US individual regarding an international insider trading investigation conducted by the SEC, resulting in a settlement with highly favorable terms. • Represented a trader from a non-US commodities trading firm in connection with a DOJ and CFTC investigation into potential commodities manipulation. Resulted in a declination of enforcement action. • Represented a US-based investment adviser in connection with an SEC examination and deficiency notice. No enforcement action was taken.

• Acted as lead counsel to a multinational pharmaceutical and healthcare company in a post-acquisition compliance review of a recent acquisition in South America • Acted as lead counsel to a multinational pharmaceutical and healthcare company in a preacquisition compliance review of a potential acquisition in Latin America. • Acted as lead counsel to a multinational logistics provider in compliance reviews of several potential acquisition targets. • Acted as lead counsel to a multinational industrial company in pre-acquisition due diligence of an acquisition in Turkey, and developing and implementing, post-acquisition, a compliance program at the Turkish operation. • Advised and assisted a multinational device and healthcare company in designing and implementing its third party compliance review process, and in conducting pre-acquisition anticorruption law diligence related to a proposed acquisition in Brazil. • Advised a multinational company in the natural resource extraction industry on preacquisition due diligence in connection with a proposed acquisition in Indonesia. Also advised this company on compliance issues in connection with its efforts to obtain a significant concession from the central government of an Asian jurisdiction. • Acted as lead counsel to a multinational vehicle manufacturer/defense company on international commercial, trade, anticorruption and compliance issues relating to its subsidiary, joint venture and dealer's operations in multiple jurisdictions, including China, India, Tunisia, Russia, Pakistan, Iraq, Venezuela, Zimbabwe and the UAE. • Acted as lead anticorruption and trade compliance counsel to a US-based transportation company in connection with the establishment of its entry into the China market, through a joint venture with Chinese state-owned-enterprise. • Acted as lead compliance and anticorruption counsel in potential acquisitions by a US-based private equity firm of companies with operations in Venezuela, Colombia, Mexico, Pakistan, and Angola, among others. • Obtained a favorable administrative ruling for a non-US financial institution relating to the receipt of funds pursuant to a letter of credit issued by a PATRIOT Act Section 311 bank from the Financial Crimes Enforcement Network.

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