Practice Areas

Navigating the High Stakes of Modern Enforcement

In today’s regulatory environment, routine business matters can rapidly escalate into government investigations. Our founding partners have operated on all sides of high-stakes investigations—as prosecutors building cases, and as defense counsel protecting individual and corporate clients in government and internal investigations alike. This 360-degree perspective enables us to anticipate moves before they happen, protect what matters most, and guide clients toward favorable resolutions.

Government Investigation Defense

We shield companies and their boards from overzealous enforcement, with services including:

• Strategic Response Management to provide you with early, thoughtful advice on the best way to navigate the investigation.
• Targeted Fact-finding so you can identify strengths and vulnerabilities before the government and build strategies around them.
• Stakeholder Communications to ensure that company management, board members, and other stakeholders are appropriately informed and involved.
• Agency Navigation in dealing with DOJ, SEC, and state regulators, leveraging our insider knowledge of how these agencies build cases in order to seek favorable resolutions.
• Litigation against the enforcers including an aggressive defense—or affirmative, preemptive civil action—when favorable negotiated resolution cannot be obtained.

Corporate Internal Investigation

We conduct discreet, thorough investigations that balance fact-finding with business continuity:

• Targeted Inquiries that address potential misconduct without unnecessary disruption.
• Board-Level Collaboration with directors, audit committees, and executives.
• Strategic Recommendations for remediation, disclosure, and defense positioning.

Individual Investigation Defense 

When companies are caught up in government investigations or conducting internal investigations, key individuals need to protect their own interests. We will:

• Assess Personal Legal Exposure to guide you through key strategic issues and to help you determine how best to deal with the company and the government as the investigation continues. 
• Navigate Your Relationship with Company Investigators to ensure your interests are protected as you are guided through an internal investigation.
• Navigate Your Relationship with Government Investigators to reduce any risk of an enforcement action against you individually.

When liberty, livelihood, or a company’s future is on the line, clients turn to Treanor Devlin Brown. Our lawyers—veterans of headline‑making trials and precedent‑setting enforcement actions—use that experience to shut down investigations early when possible and win in court when necessary.

Our legal team has significant first-chair trial experience in high-profile and complex criminal matters and deep experience in contesting regulatory enforcement matters, and we use that experience to capitalize on opportunities to advance the defense of our clients and to pursue outstanding results. 

Counsel at Treanor Devlin Brown has a range of experience managing criminal and regulatory enforcement matters in the following areas:

• Business Crimes and Fraud
• National Security, Economic Sanctions, and Export Controls
• Money Laundering and Bank Secrecy Act Violations
• Securities and Commodities Fraud, Market Manipulation, and Insider Trading
• Accounting Fraud
• Anti-Corruption
• Cybercrime
• Crypto and Blockchain
• Criminal Antitrust
• Tax Fraud
• Environmental Crimes

Standing Fearlessly Against Federal Overreach

When the awesome power of the federal government turns against its own employees, contractors, or citizens in violation of federal law or the U.S. Constitution, Treanor Devlin Brown stands ready to fight. As former federal prosecutors who proudly represented our country, we are just as prepared to bring cases against the government when it does not act as the law requires.

Defending Federal Employees and Contractors

We represent federal employees and contractors whose careers and livelihoods have been upended through:

• Terminations without individualized performance assessment.
• Reclassifications that strip hard-earned civil service protections.
• Contract cancellations without proper justification or procedure.
• Retaliatory actions against whistleblowers or dissenting voices.
• Politically-motivated removals disguised as performance issues.

When government agencies use their investigative powers to target former employees or contractors based on past work, we provide aggressive defense services:

• Challenging improper investigations that lack factual or legal basis.
• Defending against arbitrary enforcement actions.
• Protecting professional reputations from unfair smears.
• Safeguarding security clearances and professional credentials.
• Navigating complex administrative and legal proceedings.

A Litigation Approach Built on Prosecutorial Experience

Our founding partners’ extensive experience as federal prosecutors provides a decisive advantage when litigating against government entities:

• Strategic Insight: We understand government decision-making processes, legal vulnerabilities, and pressure points that others miss.
• Procedural Mastery: We navigate the complex web of administrative remedies, knowing when to exhaust them and when to bypass them.
• Relationship Capital: Our credibility with government decision-makers allows for constructive dialogue when appropriate.
• Trial Readiness: Our extensive courtroom experience means we prepare every case as if it will go to trial, creating leverage in negotiations.

Standing on Principle, Not Politics

We take cases based on legal merit, not political affiliation or ideology. Any lawyer whose primary motivation is a political goal is— by definition—putting clients second. We don’t care about your political beliefs. We don’t care about whether your case helps or hurts on some hot-button political issue. We care about you, whether your rights have been violated, and how to pursue resourse through every avenue our judicial system provides. 

A Different Kind of Government Litigation Practice

While some firms shy away from government litigation, we bring prosecutorial intensity and the strategic advantage our boutique affords.

• We’re a litigation shop. We don’t represent clients in corporate transactions where pleasing U.S. political officials is important, and we’re not subject to the conflicts that firms who do such work face. 
• We’re lean. We can pursue cases efficiently, without the cost structure and overhead larger law firms impose. 
• We’re flexible. When hourly billing is a challenge, we’ll consider flat fees and contingency fee arrangements, and where possible we’ll pursue claims under statutes that require the government to pay our fees if we are successful. 

When facing the vast resources and power of the federal government, you need counsel with the experience, courage, and strategic vision to stand firm. Treanor Devlin Brown brings the firepower and fearlessness required.

Not all litigation firms actually try cases. Treanor Devlin Brown does. 

Our founding partners have collectively tried more than 25 federal cases to verdict. We thrive in the courtroom and bring poise, credibility, and tenacity before both judges and juries. Whether in criminal or civil proceedings, our presence signals to adversaries that we are serious and prepared—which often creates leverage for favorable early resolutions.

When resolution is possible, we use our deep trial experience to negotiate strategically and effectively. When it isn’t, we stand ready to litigate with focus, intensity, and exceptional courtroom advocacy. We are also frequently called upon to partner with other law firms to help take long-running litigation matters to trial. 

Trial Experience That Speaks for Itself

Our founding partners’ courtroom credentials include:

• Complex Federal Trials Across a Range of Subjects, spanning financial fraud, insider trading, money laundering, and national security matters.
• High-Profile White-Collar Defense, including the representation of a law firm partner against cryptocurrency laundering allegations.
• Landmark Prosecutions, including the largest insider trading case ever brought to trial.
• Extended Criminal Proceedings, including multiple three-month racketeering trials that demanded sustained jury engagement and strategic evidence presentation.

Strategic Advocacy When Everything Is on the Line

When a case reaches the appellate stage, the stakes couldn’t be higher. A successful appeal can mean vindication after a devastating loss, while a failed one can cement an unfavorable judgment for years to come. At Treanor Devlin Brown, we bring decades of appellate experience to these decisive moments.

Proven Appellate Credentials

Our founding partners have collectively handled more than 25 appeals in federal appellate courts. This extensive experience gives us a profound understanding of how appellate judges approach cases and what makes arguments persuasive at this critical stage.

Dual Perspectives: Continuity and Fresh Eyes

We offer two distinct approaches to appellate representation, tailored to your specific circumstances:

Strategic Appellate Guidance Throughout Litigation

For ongoing matters, we provide forward-thinking appellate perspective from the outset:

• Issue preservation throughout trial proceedings.
• Strategic motion practice designed to position key issues optimally.
• Trial team integration that enhances appellate positioning.

New Appellate Counsel with Fresh Perspective

Sometimes fresh eyes see what others have missed. As new appellate counsel, we bring:

• Objective case evaluation unclouded by previous litigation decisions.
• Identification of novel legal theories not fully developed at trial.
• Strategic reframing of issues for appellate judges.

Comprehensive Appellate Services

Our appellate practice encompasses all phases of the appellate process:

• Record analysis to identify all potential grounds for appeal.
• Strategic issue selection focusing on arguments with the greatest likelihood of success.
• Compelling brief writing presenting complex legal issues with clarity.
• Effective oral argument leveraging our extensive courtroom experience.

Industry-Spanning Experience

Our appellate work spans the same diverse industries and subject matters as our broader practice:

• Financial services and securities regulation.
• Criminal defense and white-collar matters.
• Blockchain and cryptocurrency disputes.
• Complex commercial litigation.
• Government investigations.

The Appellate Difference

Appellate advocacy requires a different approach than trial litigation. Our team brings specialized skills to this distinct forum:

• Precision in framing legal questions that focus judges on key issues.
• Strategic legal research that finds overlooked precedent.
• Persuasive oral advocacy tailored to appellate judges’ concerns.

When the final word matters most, Treanor Devlin Brown delivers appellate representation that combines deep experience, strategic insight, and persuasive advocacy to protect your most important interests.

When a crisis explodes and threatens a business with legal peril, the first moves matter. Treanor Devlin Brown specializes in guiding individuals and companies through high-stakes crises with speed, precision, and strategic clarity.

With decades of trial and enforcement experience, we understand how investigations unfold—and how to respond. We move quickly to assess risk, shape the narrative, and protect our clients from legal, business, and reputational harm.

Our Comprehensive Crisis Response Approach

• Rapid Risk Assessment: Immediate analysis of the situation to identify exposure and mitigate risk.
• Government Engagement: Managing communications with DOJ, SEC, FBI, and other enforcement agencies.
• Internal Investigations: Conducting targeted reviews to uncover facts, preserve evidence, and shape strategy.
• Expert Collaboration: Working with technical and forensic experts on complex issues.
• Crisis Communications: Advising on sensitive internal and external messaging to safeguard reputation.
• Regulatory and Criminal Defense: Responding to subpoenas, guiding witness interviews, and building defenses for clients under scrutiny.

Balanced Expertise for Effective Monitorship Appointments

Corporate monitorships serve a critical function in the modern enforcement landscape—providing independent oversight that satisfies regulatory requirements while respecting legitimate business objectives. The success of a monitorship depends on selecting monitors who bring both credibility and pragmatism to this complex role.

Treanor Devlin Brown offers the balanced perspective essential for effective monitorship appointments. Our founding partners have extensive experience from all critical angles:

• As government prosecutors who designed monitorship frameworks and evaluated monitor performance.
• As appointed monitors overseeing compliance enhancements at major financial institutions.
• As counsel to monitored entities navigating the implementation of reform initiatives.

Our Monitorship Philosophy

Effective monitorships balance accountability with practicality. Our approach is guided by core principles:

• Independence with Understanding: maintaining objectivity while recognizing business realities.
• Rigorous but Reasonable Oversight: focusing on substantive improvements rather than box-checking.
• Clear Standards and Expectations: establishing transparent metrics for success.
• Efficient Information Gathering: minimizing operational disruption while ensuring thorough review.
• Constructive Engagement: working collaboratively while maintaining appropriate boundaries.

These principles reflect our belief that the most successful monitorships achieve meaningful reform without unnecessary business disruption or wasted time and expense—satisfying both government enforcement objectives and corporate operational needs.

Our Monitorship Services

As Appointed Monitors

When selected to serve as monitors, we bring a structured yet adaptable approach:

• Thoughtful Team Composition: assembling subject matter experts who combine technical knowledge with business. acumen; no army of junior lawyers to engage in needless work
• Transparent Work Planning: developing clear roadmaps with defined milestones and deliverables.
• Proportional Testing Methodologies: designing review protocols scaled to risk and materiality.
• Efficient Reporting Frameworks: providing meaningful insights without excessive documentation.
• Practical Recommendations: suggesting improvements that create lasting value beyond technical compliance.
• Collaborative Problem-solving: working with the monitored entity to address challenges constructively.

Our goal as monitors is straightforward: to help the company succeed in meeting obligations in the most timely and efficient way possible.

For Companies Under Monitoring

While our primary focus is serving as monitors, we also selectively advise companies navigating the monitorship process:

• Monitorship Readiness Assessments: evaluating preparedness and identifying potential challenges.
• Response Strategy Development: creating frameworks for efficient information management.
• Independent Monitorship Reviews: providing second opinions on controversial monitor findings.

Industry-Specific Monitorship Expertise

Our substantive experience across diverse regulatory contexts and industry sectors enables us to provide monitorships in a range of areas, including:

• • Anti-corruption: Compliance with FCPA, federal and state corruption laws, and international anti-corruption requirements.
  • Financial Services: BSA/AML, securities, payment service regulations, sanctions compliance, consumer protection, and market conduct.
  • Fintech/blockchain: BSA/AML, KYC, representations and conduct relating to token issuance, market making and trading, and consumer protection.

• Gaming: Federal and state gaming laws for casinos and internet operators; AML compliance; anti-corruption. 

Monitorship as a Path to Excellence

When structured appropriately, monitorships can create lasting value that extends beyond the monitoring period. Our approach focuses on:

• Sustainable Reforms: building compliance frameworks that remain effective after the monitorship concludes.
• Integration with Business Processes: embedding controls into daily operations rather than creating parallel systems.
• Enhanced Risk Awareness: developing an organizational culture that identifies issues before they become problems.
• Governance Evolution: strengthening board and management oversight capabilities for the long term.

The most successful monitorships leverage the opportunity for transformation—satisfying regulatory expectations while strengthening the organization for the future.

A Bridge Between Enforcement and Business

Effective monitors must satisfy two critical constituencies: enforcement authorities who demand genuine reform and companies who need practical, sustainable solutions. As potential monitors, we are uniquely positioned to bridge this gap—bringing enforcement credibility, business understanding, and methodical implementation to this complex role.

The rapid growth of cryptocurrencies and blockchain technology has unlocked extraordinary innovation—but it has also drawn scrutiny from law enforcement, regulators, and private litigants. Companies and individuals operating in this space often face exposure to criminal, regulatory, and financial risk. 

Enforcement authorities are focused on a range of concerns, including:

Money Laundering and AML Compliance
Cryptocurrencies present unique challenges to anti-money laundering (AML) enforcement. Businesses lacking adequate AML controls—including those operating unlicensed or unregistered as money services businesses (MSBs)—have faced prosecution. Regulators also target the use of mixing and anonymization tools designed to obscure the origins of funds.

Unregistered Securities Offerings
The SEC has aggressively pursued enforcement actions involving digital assets it deems securities, particularly in cases of fraud or misleading disclosures. Although the SEC has paused these actions while new rules are being drawn up, that hasn’t stopped state regulators and private parties from pursuing these claims, and the law in this area remains deeply unsettled. 

Fraud and Deception
Cryptocurrency markets remain rife with fraud. Common schemes include Ponzi structures, “rug pulls,” and wallet phishing scams. Prosecutors and regulators continue their efforts to hold bad actors accountable and recover losses for victims, and private parties have brought civil suits in these matters as well.

Market Manipulation
Crypto markets remain vulnerable to manipulation tactics such as wash trading, spoofing, and pump-and-dump schemes. The SEC and CFTC have made market integrity a priority, with civil lawsuits and enforcement actions targeting manipulators.

Tax Evasion and Disclosure Failures
The IRS has ramped up enforcement efforts against individuals and businesses that fail to report cryptocurrency transactions, income, or holdings—particularly those required under Form 8949 and other international reporting mandates. Non-compliance can result in audits, penalties, and potential criminal exposure.

Sanctions Evasion
OFAC has warned of cryptocurrencies being used to evade U.S. sanctions—by both state actors and blacklisted individuals. Enforcement actions continue to target blockchain-based attempts to bypass national security controls.

Cybercrime and Ransomware
Digital assets are a preferred payment method in cybercrime—from ransomware attacks to dark web transactions. Federal agencies like the FBI and DOJ are aggressively tracking illicit flows, recovering assets, and prosecuting offenders.

A Sophisticated Partner in Crypto and Blockchain Enforcement

Navigating the fast-evolving legal landscape of digital assets requires counsel with deep regulatory insight, courtroom experience, and fluency in the underlying technology. Treanor Devlin Brown offers strategic counsel to clients facing enforcement risk or seeking proactive compliance.

Our services include:

• Designing and reviewing AML programs in line with the Bank Secrecy Act, FinCEN guidelines, and Treasury regulations.
• Assessing token offerings and digital asset structures to reduce securities law exposure.
• Responding to subpoenas, government investigations, and enforcement actions involving fraud, market manipulation, or tax noncompliance.
• Guiding voluntary disclosures and regulator engagement with agencies such as the SEC, CFTC, DOJ, IRS, and OFAC.
• Conducting internal investigations while maintaining legal privilege.
• Advising on law enforcement interaction strategies, including with federal agencies and financial crime units.

With extensive experience in white-collar defense and regulatory enforcement, and a track record of representing blockchain companies and their executives, Treanor Devlin Brown is trusted to deliver decisive, informed advocacy in this complex and rapidly changing space.

The AI revolution isn’t coming—it’s here. As former federal prosecutors who’ve witnessed firsthand how disruptive technologies outpace regulatory frameworks, we’ve built a practice specifically designed to help AI companies thrive in this uncertain landscape.

True Believers in AI’s Transformative Power

At Treanor Devlin Brown, we don’t just practice AI law—we actively engage with the technology and its evolution. Our founding partners are passionate followers of AI development, regularly exploring new capabilities and monitoring industry advancements. We’ve experienced firsthand how AI tools are revolutionizing legal practice, enabling our boutique law firm to punch well above our weight and pass the savings on to clients. 

This isn’t just professional interest—it’s personal commitment to understanding the technology reshaping our world. When you work with us, you won’t waste valuable time educating your lawyers on how the models work or the latest industry developments shaping the legal issues. We speak your language and stay current with both technical developments and their legal implications.

Why AI Companies Need Specialized Legal Counsel

AI development exists at the intersection of unprecedented opportunity and evolving legal risk. Your company faces a complex matrix of challenges:

Regulatory Uncertainty and Enforcement Risk

• Inconsistent Regulatory Frameworks: While the EU races ahead with the AI Act, the U.S. approach remains fragmented across federal agencies and state laws. We translate this patchwork into actionable compliance strategies.
• National Security Scrutiny: As AI becomes central to geopolitical competition, your technology faces heightened scrutiny under export controls and CFIUS reviews. We’ve successfully navigated these waters for technology companies facing similar challenges.
• Government Engagement: We help you engage proactively with regulators and authorities before enforcement actions materialize, drawing on our decades of experience as both prosecutors and defense counsel.

Novel Legal Questions That Demand Creative Solutions

• Intellectual Property Challenges: The legal boundaries around training data, model outputs, and copyright are being redrawn in real time. Our litigation experience positions us to anticipate how courts will resolve these unsettled questions.
• Products Liability and First Amendment Tensions: When AI generates content that causes harm, what legal standards apply? These and other novel legal questions will likely be resolved in what may become a wave of new litigation. 
• Law Enforcement and Regulatory Demands: Government access to AI queries and outputs presents novel privacy and compliance challenges. We’ve advised technology companies on these issues and helped them develop positive relationships with law enforcement.

AI Legal Services

Strategic Risk Assessment and Compliance Design

Before problems arise, we identify your most significant legal vulnerabilities and develop targeted compliance frameworks. Our approach is practical and business-focused—designed to protect innovation, not impede it.

Crisis Response and Enforcement Defense

When regulatory scrutiny or litigation threatens your AI business, we bring prosecutorial intensity and strategic vision to your defense. Our founding partners have:

• Successfully defended technology companies against novel theories of liability.
• Negotiated favorable regulatory settlements that preserved business models.
• Transformed potential enforcement disasters into manageable compliance frameworks.

Litigation Strategy for Novel AI Issues

When precedent-setting litigation is unavoidable, we bring deep trial experience to complex, technology-focused cases. Whether defending against claims or pursuing affirmative litigation to protect your interests, we understand both the technology and the evolving legal framework.

A Future-Focused Partnership

The legal challenges your AI company faces today will evolve as rapidly as your technology. We offer more than point-in-time legal advice—we provide ongoing strategic counsel that anticipates regulatory shifts, enforcement trends, and litigation risks before they materialize.

Choose Treanor Devlin Brown for AI legal counsel that matches your technology’s sophistication with legal strategies built for tomorrow’s challenges.

Strategic Legal Counsel for High-Stakes Cyber Incidents

When companies face intrusions, ransomware attacks, or data breaches, the response must be immediate, coordinated, and legally sound. These events can halt operations, compromise sensitive data, and trigger complex regulatory obligations. Treanor Devlin Brown helps clients navigate these critical moments with clarity and control.

Our Approach

We work quickly to minimize disruption, reduce legal and financial exposure, and preserve reputation. Our attorneys advise on every phase of incident response in close coordination with IT, forensics, PR, and executive teams.

Our Services Include:

• Leading internal investigations to determine the scope and cause of the incident.
• Collaborating with technical experts to collect and analyze digital evidence.
• Advising on legal obligations under federal, state, and international data privacy laws.
• Managing internal and external communications to mitigate reputational harm.
• Reporting incidents to regulators and coordinating with law enforcement where mandatory or desired.
• Defending against litigation and enforcement actions arising from the incident.

Why Treanor Devlin Brown?

We bring deep experience in cybercrime and crisis management. Our founders have advised fintech startups, public companies, and global media organizations on their legal response to ransomware attacks, data theft, and high-impact breaches. With strong relationships across government and a sharp command of cyber risk law, we guide clients to resolution while protecting their operations, assets, and long-term interests.

Former federal prosecutors who recovered billions for fraud victims now stand ready to protect your interests in high-stakes civil disputes. 

Civil Defense That Anticipates Every Move

When facing complex litigation, your defense team must be prepared to litigate hard and try a case where necessary to get the best result.

We defend against:

• Commercial Disputes: Addressing contract breaches and business tort claims.
• Civil RICO Challenges: Neutralizing complex racketeering allegations with investigative rigor and technical expertise.
• Whistleblower Actions: Countering False Claims Act suits with government-grade scrutiny of claims and credibility.
• Regulatory Proceedings: Converting agency actions into manageable challenges through our deep regulatory fluency.

Affirmative Litigation That Delivers Results

Some wrongs demand more than defense—they require aggressive pursuit of justice and compensation. When you’ve been harmed, we deploy the same prosecutorial mindset that recovered billions in landmark cases to deliver results for you now.

Our plaintiff-side practice focuses on high-impact matters:

• Civil RICO Actions: Unraveling complex schemes that damaged your business or investments.
• Anti-Terrorism Act Claims: Pursuing accountability and compensation for victims of terrorism and its enablers.
• Whistleblower Representation: Exposing fraud against government programs while protecting whistleblowers.
• Foreign Judgment Enforcement: Converting international victories into tangible asset recovery.
• Strategic Class Actions: Amplifying the power of collective claims while maintaining individual client focus.
• Contingency Arrangements: Aligning our success with yours through risk-sharing fee structures.

Boutique Efficiency, AmLaw 50 Firepower

We deliver the best of both worlds:

• Principal-Led Representation: You hire us, you get our attention—for the strategy sessions and the courtroom battles that matter most.
• Technology as a Multiplier: Our AI-powered document analysis and case management systems handle the volume so our attorneys can focus on substance.
• Nimble Staffing Model: We scale precisely to case demands, staffing from within where suitable and partnering with outside providers where cost savings are possible or a key outside resource is necessary.
• Value-Based Pricing: Our fee structures reflect the results we deliver, not just the hours we spend.

Whether defending against claims or pursuing justice on your behalf, we bring prosecutorial intensity, trial-tested judgment, and boutique agility to deliver the outcomes that matter to you.

When assets have been stolen, hidden, or fraudulently transferred, we find them and get them back.

From Secrecy to Transparency: The New Asset Recovery Landscape

The walls protecting hidden assets are crumbling. Global transparency initiatives have weakened secrecy laws that once shielded shell companies, nominee directors, and undisclosed transactions. For victims of fraud and misconduct, this creates unprecedented opportunities to trace and recover assets that were previously beyond reach.

Battle-Tested Recovery Experience

Treanor Devlin Brown brings prosecutorial intensity and litigation precision to asset recovery. Our founding partners have:

• Recovered billions for victims through both criminal and civil proceedings.
• Secured over $200 million for FIFA and global football organizations from corrupt administrators and their business partners.
• Navigated complex international financial systems to trace assets across jurisdictions and ownership structures.
• Developed relationships with global law enforcement and international law practices to coordinate cross-border recovery efforts.

Comprehensive Recovery Strategies

We deploy a full spectrum of tools to recover what’s rightfully yours:

• Asset Seizure Actions: Freezing and securing bank accounts and physical assets.
• Seeking Assets Seized in Criminal Proceedings: Navigating remission and restoration processes to claim priority on forfeited assets.
• Third-Party Claims: Asserting your rights in ancillary proceedings.
• Strategic Civil Litigation: Pursuing fraudsters through targeted lawsuits when criminal processes aren’t available or sufficient.

Global Reach, Local Execution

Asset recovery demands both international capabilities and localized expertise. Our network of international partners extends our reach across jurisdictions, allowing us to:

• Trace assets through complex offshore structures.
• Navigate local legal systems with precision.
• Employ jurisdiction-specific recovery tactics that maximize effectiveness.
• Coordinate multi-jurisdictional efforts for comprehensive recovery.

Whether you’re pursuing assets stolen through corporate fraud, investment schemes, or corruption, Treanor Devlin Brown brings the experience, determination, and global capabilities needed to turn legal victories into actual financial recovery.

Thoughtful Counsel for Consequential Decisions

Few people set out to be whistleblowers. But when individuals encounter potential wrongdoing in their professional lives, they face complex legal, ethical, and personal considerations. These situations demand advisors who understand the range of choices available and can provide guidance on which to pursue. 

At Treanor Devlin Brown, we offer sophisticated representation informed by our experience on all sides of these matters.

Balanced Perspective from All Sides

Our founding partners bring diverse experience to whistleblower matters:

• As federal prosecutors in the nation’s premier U.S. Attorney’s Office, we met with and evaluated claims of company insiders, relying on credible and substantial reports to build cases that recovered billions for fraud victims.
• As defense counsel to major corporations, we’ve helped companies respond effectively to whistleblower allegations and, where substantiated, helped address the problem.
• As advisors to individuals, we’ve guided individuals aware of (and sometimes involved in) corporate wrongdoing through the complex decision-making process concerning whether to report the issue outside of the company. 

This 360-degree perspective allows us to provide nuanced counsel that accounts for all relevant considerations—legal, professional, and personal. We understand what makes cases compelling to government agencies, how companies respond to allegations, and what factors individuals should weigh before making disclosures.

Measured Approach to Complex Decisions

Whistleblowing represents one of the most consequential professional decisions an individual can make. Before taking this step, clients benefit from thorough evaluation of all potential pathways and implications. Our approach includes:

• Comprehensive risk assessment of personal and professional considerations.
• Exploration of alternative resolution options where appropriate.
• Strategic planning for those who decide to proceed with disclosures.
• Careful navigation of confidentiality concerns and potential anonymity.
• Thoughtful management of potential exposure to related proceedings.
• Clear explanation of potential financial incentives without overpromising outcomes.

Federal Whistleblower Programs:

Department of Justice (DOJ) Whistleblower Programs

Launched in 2024, these groundbreaking programs target white-collar crime with incentives for insiders who step forward.

The DOJ now offers both immunity from prosecution for cooperating wrongdoers and in some cases financial rewards for those who report misconduct, alongside robust anti-retaliation protections. How these programs will work in practice is still unclear, but we can guide you through the analysis. 

Securities & Commodities Whistleblowers (SEC, CFTC)

These programs have awarded hundreds of millions of dollars to individuals who exposed securities fraud, market manipulation, FCPA violations, and commodities misconduct. Awards range from 10% to 30% of monetary sanctions exceeding $1 million, with strong confidentiality protections including anonymous filing options.

Treasury Department (FinCEN) AML and Sanctions Program

This newer program targets financial crimes with rewards of 10% to 30% on recoveries exceeding $1 million. While implementing regulations are still developing, we monitor this evolving program closely to position clients advantageously.

False Claims Act (FCA) Whistleblower Program

Dating to 1863, the FCA’s qui tam provisions have recovered billions from government contractors and others who defraud taxpayers. Whistleblowers receive 15% to 30% of recoveries, which can be multiplied by treble damages and civil penalties. The FCA’s global reach extends to misconduct worldwide and welcomes non-U.S. whistleblowers.

IRS Whistleblower Program

This program has awarded billions to whistleblowers who identified significant tax evasion. Awards range from 15% to 30% of collected amounts, providing substantial incentives to expose non-compliance.

Our Deliberate Process

1. Initial Consultation and Assessment

We help you understand the full landscape of options, evaluate the strength of potential disclosures, and assess both risks and potential benefits of various approaches.

2. Exploration of Alternatives

In appropriate cases, we discuss potential alternatives to formal whistleblowing, including internal reporting channels and other resolution mechanisms.

3. Thoughtful Decision-Making

We provide the guidance needed to make an informed decision aligned with your values, priorities, and circumstances—with no pressure in either direction.

4. Strategic Implementation

For clients who choose to proceed with disclosures, we develop and execute a careful strategy that protects your interests throughout the process.

5. Ongoing Representation

We provide steady counsel through what can be a lengthy and complex process, managing expectations and advocating for your interests at every stage.

Informed Decisions. Sound Guidance.

Complex situations involving potential misconduct require careful navigation. Our experience on all sides of these matters provides the perspective needed for thoughtful counsel.

Prevention Is the Best Defense

At Treanor Devlin Brown, we know firsthand what happens when compliance programs fail. As former federal prosecutors who built large-scale enforcement cases, we’ve seen the devastating consequences of regulatory blind spots—nine-figure penalties, criminal charges, reputational damage, and operational disruption.

Today, we leverage that prosecutorial insight to build compliance shields that protect our clients before problems arise.

The Former Prosecutor’s Advantage in Compliance

Our compliance approach is fundamentally different because we’ve stood in the government’s shoes. We know:

• How enforcement priorities are set and where investigators look first.
• Which compliance gaps trigger the harshest penalties.
• How to distinguish between technical violations and true enforcement risks.
• When self-disclosure makes sense—and when it doesn’t.

This insider perspective informs every aspect of our compliance counseling, from policy design to risk assessment to training programs that actually change behavior.

Targeted Expertise in High-Risk Domains

Insider Trading Compliance

The line between legitimate market research and illegal insider trading is sometimes blurred. We’ve investigated and prosecuted some of the largest insider trading cases of all time, and on the defense side we’ve helped numerous Fortune 100 companies and leading investment firms navigate the compliance landscape. We offer: 

For Investment Firms:

• Pre-Transaction Risk Assessment: Evaluating potential investments for material non-public information concerns.
• Expert Network Protocols: Establishing guidelines for legitimate market intelligence gathering.
• Trading Pattern Analysis: Identifying and addressing trading activities that could trigger regulatory scrutiny.
• Rapid Response Counsel: Providing immediate guidance when potential insider trading issues emerge.

For Corporate Issuers:

• Internal Policies and Controls: Designing frameworks to prevent employee insider trading.
• Blackout Period Management: Establishing clear guidelines around earnings and material events.
• Employee Education: Creating training that resonates with executives and employees alike.
• Incident Response: Guiding companies through internal investigations when potential violations occur.
• Regulatory Engagement: Representing corporate victims in SEC and DOJ enforcement processes.

Anti-Corruption & FCPA

Global business demands global compliance. We design anti-corruption programs that work in practice, not just on paper:

• Risk-Calibrated Due Diligence: Focusing resources where corruption risk is highest.
• Practical Third-Party Controls: Building verification systems that detect red flags without crippling operations.
• Effective Training Programs: Creating scenario-based education that resonates with employees in high-risk roles.
• Post-Acquisition Integration: Quickly bringing acquired entities into compliance with minimal business disruption.

Financial Crime Compliance

The anti-money laundering landscape has transformed, with enforcement priorities shifting and penalties escalating. Working with outside AML/BSA consulting experts, we can assist in creating risk-based programmatic protections in BSA/AML Program Design, Suspicious Activity Reporting, and KYC and Customer Due Diligence scenarios that minimize false positives while catching genuine risks.

Economic Sanctions & Export Controls

With sanctions increasingly weaponized as foreign policy tools, compliance has never been more complex—or more crucial. Working with outside experts, we can help ensure that OFAC compliance guidance is tailored to the true risks of enforcement action. 

Cannabis Industry Compliance

As cannabis regulation evolves across federal and state jurisdictions, we provide clarity in this rapidly changing landscape:

• Multi-Jurisdictional Compliance: Navigating the complex interplay between federal prohibition and state legalization.
• Banking and Financial Services Access: Developing compliance frameworks that satisfy financial institution requirements.
• Investment and M&A Due Diligence: Assessing compliance risks in cannabis industry transactions.

When Problems Arise: A Seamless Transition to Defense

Despite best efforts, compliance issues can still emerge. When they do, our clients benefit from seamless access to our enforcement defense team—attorneys who understand both the compliance framework and the enforcement landscape, enabling rapid response and strategic remediation.

A Partnership Approach

We view compliance not as a legal service but as a strategic partnership. Our clients don’t just receive manuals and training materials—they gain ongoing access to advisors who understand both the regulatory landscape and their specific business model.

Treanor Devlin Brown possesses unique expertise in corporate compliance monitorships, having engaged in monitorships from every perspective. Tim Treanor, for example, as a prosecutor, installed and managed one of the first monitorships required by the Department of Justice (DOJ); he later served as lead counsel on the team monitoring HSBC Bank for a five-year period; and he separately has advised and represented numerous companies under monitorships, including major international banks and public companies. This broad perspective allows our firm to effectively assist clients in navigating the challenges associated with monitorships.

We provide strategic guidance on meeting monitorship requirements, managing interactions with monitors, and implementing sustainable compliance enhancements to satisfy the expectations of regulators and enforcement agencies. Treanor Devlin Brown is dedicated to helping companies achieve successful outcomes while minimizing disruption and maintaining the integrity of their operations.

Treanor Devlin Brown provides experienced representation in appellate matters. Our appellate practice focuses on analyzing trial records, identifying key legal issues, preparing well-reasoned briefs, and delivering excellence in oral arguments. We assist clients in seeking to overturn adverse decisions or defending favorable judgments, providing clear guidance and effective advocacy throughout the appellate process.