Sharon M. Bunzel

Representations of corporations, special board committees and individuals in internal investigations of allegations of federal and state law violations. Develop recommendations for remedial actions and compliance programs. Recent representations include a multinational consumer products company in an investigation of whistleblower allegations implicating business practices across Asia; a multinational technology company responding to a web of inquiries from federal, state and local enforcement agencies, including the Department of Justice, multiple state Attorneys General, and District Attorneys, on issues including FCPA, wire and securities fraud, data privacy, consumer fraud and unfair business practices; the audit committee of one of the largest energy sector companies in the world in response to shareholder False Claims Act allegations; a multinational e-commerce corporation in an internal investigation involving anti-money laundering issues; and one of the largest health club companies in California in connection with an investigation in response to District Attorney claims of unfair business practices and false advertising.

Representations of multinational companies and US companies with international business transactions in responding to whistleblower allegations and government inquiries regarding potential anti-corruption and export control violations, including internal investigations, self-reporting to the Securities and Exchange Commission and the Department of Justice, and developing corporate compliance programs. Recent experience includes representation of audit committee of US semiconductor company with operations in China in whistleblower investigation involving allegations of FCPA and export control violations.

Representations of corporate victims of trade secret misappropriation and computer fraud in pursuing civil and criminal remedies, and of corporate targets of FBI trade secret theft investigations and related internal investigations, criminal prosecutions, and civil litigation. Recent representations include major technology company in connection with DOJ investigation of trade secret theft by employee who allegedly brought information obtained during prior employment with competitor; implemented disciplinary and remedial measures, with no prosecution against company. Also recently represented victim companies in technology and executive search industries in obtaining restitution in criminal trade secret prosecutions against former employees, and victim companies in data breach matters.

Individual and corporate representations of targets in DOJ Antitrust Division investigations of the freight forwarding, air cargo, LCD panel, and DRAM industries.

Representations of high-level employees and executives in stock options backdating and securities fraud investigations, and related criminal, civil, and regulatory matters. Recent representations include a public company Controller in connection with insider trading claims brought by SEC; a Board member of a so-called “unicorn” company under investigation by the SEC for fraud; a for-profit education company executive in connection with an SEC probe related to disclosures of student placement information; and the head of the Mergers and Acquisitions Tax Department of a Big Four accounting firm in an SEC investigation, in which the SEC dismissed all charges after commencement of litigation.

Corporate and individual representations in criminal investigations and civil suits for off-label marketing of pharmaceuticals, False Claims Act violations, and health-care fraud. Recent experience includes high-level executive in criminal investigation related to off-label marketing, where prosecution was avoided.

Corporate representations in connection with Attorney General and District Attorney allegations of California’s Unfair Business Practices, false advertising, and weights and measurement laws. Recent experience includes representation of a large online retailer in connection with an investigation and statewide resolution of allegations regarding misrepresentations of sales terms advertised on its website, and representation of one of the largest health club companies in California in connection with the investigation and statewide resolution of claims of unfair business practices and false advertising, including oversight of restitution and remedial measures.

Representation of companies in connection with grand jury proceedings, including counseling with respect to witness and document subpoenas, testimony, and government interviews.