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:

• “FCPA Enforcement Against U.S. and Non- U.S. Companies,” 8  & Entrepreneurial L. Rev.353 (2019) (with Michael Diamant and Jason Smith);
• “Corporate Monitors and the Monitorship Process” in From ‘Baksheesh’ to Bribery: Examining the Global Fight Against Corruption and Graft (T. Markus Funk & Andrew S. Boutros eds., Oxford UP 2019) (with F. Joseph Warin and Michael Diamant);
• “Sanctionable Practices at the World Bank: Interpretation and Enforcement,” 18  J. Bus. L.985 (2016) (with Michael Diamant and Jason Smith); and
• “Decoding FCPA Enforcement: The U.S. Government Issues Comprehensive Guidance on the Foreign Corrupt Practices Act,” Insights: The Corporate and Securities Law Advisor (Vol. 26; December 2012) (with F. Joseph Warin and Michael Diamant).

Mr. Sullivan’s recent speaking engagements include the following:

• “FCPA 2020 Year-End Update” (January 2021) Gibson Dunn Webcast;
• “Corporate Compliance and U.S. Sentencing Guidelines” (November 2020), Gibson Dunn Webcast;
• “Managing Internal Audit and Investigations” (November 2020), Gibson Dunn Webcast;
• “World Bank Enforcement: Considerations for Companies Accepting Development Funding” (September 2020), KPMG-Gibson Dunn Webinars for US/EU and Asia; and
• “FCPA Flash Podcast – A Conversation With John Chesley and Chris Sullivan Regarding 2019 FCPA And Related Developments” (January 2020), FCPA Professor.

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.