REPRESENTATIVE EXPERIENCE
Michael Culhane Harper
Private Practice
Obtained rare post-indictment deferred prosecution agreement for the former CEO and Board
Chairman of Russia’s largest privately held banking group after making widespread challenges to
the government’s evidence and obtaining a suppression order in a criminal enforcement matter
brought by DOJ’s KleptoCapture Task Force and the US Attorney’s Office for the Southern District
of New York alleging violation of the International Emergency Economic Powers Act (IEEPA).
Representing an international finance executive who was indicted for allegedly operating an
unlicensed money transmitting business and making false statements to a bank. The matter is
being prosecuted out of the Northern District of California.
Leading government-facing investigation for national retail company in connection with a US
Customs and Border Protection investigation into potential customs duties violations.
Conducted anti-corruption due diligence, as well as anti-corruption and compliance reviews and
risk assessments, for multinational publicly traded companies across industries.
Prepared anti-corruption compliance policies and procedures, including training materials and
third-party agreements, for multinational publicly traded companies across industries.
DOJ Experience
Led the DOJ’s investigation and prosecution in a landmark FCPA enforcement action against a
publicly traded global telecommunications company for FCPA violations in Asia, Africa, and the
Middle East, resulting in a guilty plea and a coordinated resolution with the SEC. The matter
was prosecuted in the Southern District of New York.
Led the DOJ’s investigation and prosecution of a Colombian investment bank for FCPA violations,
resulting in a deferred prosecution agreement in the US, the first-ever coordinated resolution
with authorities in Colombia, as well as a coordinated resolution with the SEC. The matter was
prosecuted in the Eastern District of New York.
Led the DOJ’s investigation and prosecution of a Brazil-based investment company for FCPA
violations, resulting in a parent-level guilty plea, as well as a coordinated resolution with
the SEC. The matter was prosecuted in the Eastern District of New York.
Member of the trial team in securing guilty verdicts against the former National Treasurer of
Venezuela and her husband for their roles in a multibillion-dollar bribery and money laundering
scheme. The matter was prosecuted in the Southern District of Floria.
Lead trial lawyer in securing guilty verdict for bank fraud, mail fraud, and aggravated identity
theft against a defendant in a loan fraud scheme. The matter was prosecuted in the Eastern
District of Virginia.
