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Courtney M. Brown

Courtney
Brown

Partner

CONTACT INFO

cmbrown@gibsondunn.com

TEL:+1 202.955.8685

FAX:+1 202.530.9609

Washington, D.C.

1050 Connecticut Avenue, N.W., Washington, DC 20036-5306 USA

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PRACTICE

White Collar Defense and Investigations Crisis Management FDA and Health Care Financial Institutions International Trade Litigation Securities Enforcement

BIOGRAPHY

Courtney M. Brown is a partner in the Washington, D.C. office of Gibson, Dunn & Crutcher, where she practices primarily in the areas of white collar criminal defense and corporate compliance.  Ms. Brown has experience representing and advising multinational corporate clients and boards of directors in internal and government investigations on a wide range of topics, including anti-corruption, anti-money laundering, sanctions, securities, tax, and “me too” matters.

Selected investigation and enforcement matters include:

  • Represented a multinational information technology company in negotiating resolutions of claims brought by the U.S. Department of Justice (“DOJ”) and Securities and Exchange Commission (“SEC”) under the U.S. Foreign Corrupt Practices Act (“FCPA”), including successful completion of a post-resolution reporting period.
  • Conducted an investigation for the Board of Directors involving allegations of insider dealing against executives.
  • Represented a global financial institution in a multi-agency investigation concerning the U.S. Treasuries market.
  • Conducted a workplace investigation on behalf of a Special Committee of the Board of Directors.
  • Represented an investment manager in an SEC investigation involving allegations of false advertising and other misconduct under securities regulations.
  • Represented a defense company, obtaining declinations of criminal and civil enforcement actions by the DOJ and SEC in FCPA investigations, as well as the dismissal of an employment lawsuit brought by a former employee.
  • Obtained declinations, on behalf of a Fortune 500 company, of criminal and civil enforcement actions by the DOJ and SEC in a joint FCPA investigation arising from whistleblower complaints.
  • Represented banks and asset managers in investigations by the DOJ, SEC, congressional committees, and state investigators relating to subprime mortgage matters and the Madoff fraud.

Ms. Brown also counsels corporations on the effectiveness of their compliance programs and in connection with transactional due diligence, with a particular emphasis on compliance with anti-corruption laws, anti-money laundering regulations, and economic and trade sanctions administered by the U.S. Department of Treasury’s Office of Foreign Assets Control.

Ms. Brown has participated in two government-mandated FCPA compliance monitorships and conducted anti-corruption and compliance trainings for in-house counsel and employees.  She also has experience advising companies on the application of the U.S. Sentencing Guidelines and, since 2014, has been a contributing author for the ABA’s treatise, “Practice Under the Federal Sentencing Guidelines.”

Ms. Brown completed a secondment at a Fortune 100 company, where she advised global legal and business teams on compliance with anti-corruption laws.

Ms. Brown received her law degree in 2008 from the University of Chicago Law School.  Prior to law school, Ms. Brown worked for the Chairman of the U.S. Senate Health, Education, Labor and Pensions Committee.  Ms. Brown earned her undergraduate degree from Harvard University, where she was co-captain of the NCAA Division I championship women’s crew team and an All-American selection in rowing.

Ms. Brown is a member of the bars of the District of Columbia and Virginia.

 

EDUCATION

University of Chicago - 2008 Juris Doctor

Harvard University - 2003 Bachelor of Arts

ADMISSIONS

District of Columbia Bar

RECENT PUBLICATIONS

Client Alert - February 3, 2022 | 2021 Year-End Update on Corporate Non-Prosecution Agreements and Deferred Prosecution Agreements
Client Alert - December 13, 2021 | U.S. Strategy on Countering Corruption Signals Focus on Enforcement
Press Releases - November 4, 2021 | Gibson Dunn Promotes 27 Lawyers to Partnership
Webcasts - October 18, 2021 | Webcast: Negotiating Closure of Government Investigations: NPAs, DPAs, and Beyond
Webcasts - September 14, 2021 | Webcast: National Security Enforcement: Developments and Trends
Client Alert - July 22, 2021 | 2021 Mid-Year Update on Corporate Non-Prosecution Agreements and Deferred Prosecution Agreements
Webcasts - February 4, 2021 | Webcast: White Collar Enforcement Outlook 2021 – Sanctions/Export Controls, AML and Healthcare Fraud
Client Alert - January 19, 2021 | 2020 Year-End Update on Corporate Non-Prosecution Agreements and Deferred Prosecution Agreements
Client Alert - January 14, 2021 | Small Business Administration Publishes Interim Final Rules for First Draw and Second Draw PPP Loans
Client Alert - December 23, 2020 | Coronavirus Relief Package Passed by Congress Would Revive Paycheck Protection Program and Provide Additional Relief to Eligible Businesses
Webcasts - November 12, 2020 | Webcast: Managing Internal Audit and Investigations
Webcasts - October 1, 2020 | Webcast: Negotiating Closure of Government Investigations: NPAs, DPAs, and Beyond
Client Alert - July 15, 2020 | 2020 Mid-Year Update on Corporate Non-Prosecution Agreements and Deferred Prosecution Agreements
Client Alert - June 8, 2020 | President Signs Paycheck Protection Program Flexibility Act
Client Alert - June 3, 2020 | DOJ Updates Guidance Regarding Its “Evaluation of Corporate Compliance Programs”
Client Alert - May 18, 2020 | Small Business Administration Publishes Loan Forgiveness Application
Client Alert - April 29, 2020 | Small Business Administration Publishes Additional Interim Final Rules and New Guidance Related to PPP Loan Eligibility and Accessibility
Client Alert - April 9, 2020 | Analysis of Small Business Administration Memorandum on Affiliation Rules and FAQs on Paycheck Protection Program
Client Alert - April 4, 2020 | Small Business Administration Issues Interim Final Rule on Affiliation, Summary of Affiliation Tests, Lender Application Form and Agreement, and FAQs for Paycheck Protection Program
Client Alert - April 3, 2020 | Small Business Administration Issues Interim Final Rule and Final Application Form for Paycheck Protection Program
Client Alert - April 1, 2020 | Small Business Administration and Department of Treasury Publish Paycheck Protection Program Loan Application Form and Instructions to Help Businesses Keep Workforce Employed
Client Alert - March 26, 2020 | Senate Advances the CARES Act, the Largest Stimulus Package in History, to Stabilize the Economic Sector During the Coronavirus Pandemic
Client Alert - January 8, 2020 | 2019 Year-End Update on Corporate Non-Prosecution Agreements and Deferred Prosecution Agreements
Client Alert - January 10, 2019 | 2018 Year-End Update on Corporate Non-Prosecution Agreements and Deferred Prosecution Agreements
Client Alert - July 10, 2018 | 2018 Mid-Year Update on Corporate Non-Prosecution Agreements (NPAs) and Deferred Prosecution Agreements (DPAs)
Client Alert - April 12, 2018 | Trump Administration Imposes Unprecedented Russia Sanctions
Client Alert - January 4, 2018 | 2017 Year-End Update on Corporate Non-Prosecution Agreements (NPAs) and Deferred Prosecution Agreements (DPAs)
Client Alert - July 11, 2017 | 2017 Mid-Year Update on Corporate Non-Prosecution Agreements (NPAs) and Deferred Prosecution Agreements (DPAs)
Client Alert - July 6, 2016 | 2016 Mid-Year Update on Corporate Non-Prosecution Agreements (NPAs) and Deferred Prosecution Agreements (DPAs)
Client Alert - July 6, 2016 | Beneficial Ownership and Customer Due Diligence:  Perspectives on the Increased Compliance Risk Associated with the Implementation of FinCEN’s Final Rule
Client Alert - January 5, 2016 | 2015 Year-End Update on Corporate Non-Prosecution Agreements (NPAs) and Deferred Prosecution Agreements (DPAs)
Article - October 26, 2015 | SEC Picks Up The Pace On Financial Reporting Fraud Efforts
Client Alert - January 6, 2015 | 2014 Year-End Update on Corporate Non-Prosecution Agreements (NPAs) and Deferred Prosecution Agreements (DPAs)
Client Alert - January 2, 2013 | 2012 Year-End FCPA Update
Client Alert - November 19, 2012 | Decoding FCPA Enforcement: The U.S. Government Issues Comprehensive Guidance on the Foreign Corrupt Practices Act
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