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 blindspots—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 a blurry one. 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. enarios 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.