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Christopher W.H. Sullivan is of counsel in the Washington, D.C., office of Gibson, Dunn & Crutcher. He practices in the firm’s Litigation Department and is a member of the White Collar Defense and Investigations Practice Group. His practice focuses on white collar criminal defense, internal investigations, and corporate compliance.
Mr. Sullivan has significant experience representing and advising multinational companies in internal and government investigations, enforcement proceedings, and corporate compliance monitorships. He has represented clients in a variety of areas, including False Claims Act, Foreign Corrupt Practices Act, public corruption, and OFAC matters, before the Department of Justice, Securities and Exchange Commission, and other enforcement authorities. Mr. Sullivan has conducted internal investigations regarding potential corruption, sanctions, False Claims Act, and other white collar issues. He regularly advises public companies on the structure and effectiveness of their anti-corruption compliance programs, including policies and procedures, third-party due diligence systems, benchmarking, and corruption risk assessments, and in connection with conducting compliance program reviews and pre- and post-acquisition due diligence. Mr. Sullivan held a leadership role in a major FCPA compliance monitorship, has counseled several companies in connection with navigating compliance monitorships, and has conducted training for in-house compliance professionals. Mr. Sullivan also has significant World Bank enforcement experience, working on behalf of clients under investigation by the World Bank Integrity Vice Presidency and assisting companies already subject to World Bank sanction.
Mr. Sullivan writes and speaks on issues related to compliance and enforcement. Mr. Sullivan authors, with his colleagues at Gibson Dunn, the Firm’s biannual FCPA Updates.
Mr. Sullivan’s recent publications include the following:
Mr. Sullivan’s recent speaking engagements include the following:
Mr. Sullivan clerked for the Honorable Deborah Cook of the U.S. Court of Appeals for the Sixth Circuit and for the Honorable Brent Dickson of the Indiana Supreme Court. Mr. Sullivan received his law degree from Washington University in 2007, where he served as an Executive Editor of the Law Review, was a legal writing teaching assistant, earned the Samuel M. Breckenridge Book Award for Excellence in Legal Writing, and was elected to the Order of the Coif. He is a 2003 magna cum laude graduate of Miami University.
Mr. Sullivan is a member of the bars of the District of Columbia and Ohio.
Washington University in St. Louis - 2007 Juris Doctor
Miami University - 2003 Bachelor of Science
District of Columbia Bar