Gregory A. Paw, a partner with Pepper Hamilton LLP, is an experienced trial lawyer with extensive white collar experience. A former Deputy U.S. Attorney and past director of the New Jersey Division of Criminal Justice, Mr. Paw is a member of the Pepper’s White Collar and Corporate Investigations Practice Group. He also is a member of the firm’s Business Integrity Practice Group.
Mr. Paw represents businesses and individuals facing investigation by federal and state law enforcement authorities, and provides counsel on compliance and control issues. Drawing on his extensive and unique international law enforcement experience, he advises businesses on compliance issues under the Foreign Corrupt Practices Act (FCPA). Mr. Paw has served as counsel to a court-appointed monitor reviewing FCPA compliance issues in the global operations of a Fortune 100 company. He also has guided clients through a host of challenges in international business operations. For example, he has:
- engaged in FCPA investigations and due diligence reviews for international companies facing compliance issues
- conducted an internal investigation for an international health care company to determine whether improper kickbacks were being paid, and to advise on best practices for structuring relationships with joint venture partners
- represented an employee of a multinational company in an FCPA and antitrust investigation, resulting in no charges being filed against the employee
- guided a distinguished private university through a suit by a state attorney general who alleged mismanagement by the school, resulting in a favorable outcome including implementation of governance changes deemed “impressive” and “state-of-the-art” by nonprofit management experts
- represented an international business exporting technology to Latin America concerning compliance, banking and regulatory issues
- supervised an internal investigation for an international pharmaceutical company on a data security issue, and helped implement revisions to the company’s compliance program
- led an internal investigation for a multinational engineering firm to review potential environmental and compliance issues in the firm’s operations
- led an internal investigation for a large pharmaceutical company to assess potential wrongdoing by company employees
- conducted internal investigation of racial and ethnic violence at a local high school, coordinating a review of the law enforcement response to the events
- led a private school through an internal investigation and forensic accounting after the school discovered mismanagement by its business manager
- engaged in an internal investigation and asset recovery for a nonprofit center that suffered loss caused by its former controller
- conducted an internal investigation and provided guidance to an international manufacturer on export compliance issues with the Office of Foreign Assets Control and the U.S. Bureau of Industry and Security
- reviewed data privacy and access issues for a national shipping firm, and provided advice on ensuring compliance with applicable laws
- consulted with businesses and individuals on international banking and taxation issues arising from business in Switzerland
- represented a large health care system in the course of a fraud investigation, resulting in a decision to close the criminal investigation without any charges
- represented an agricultural association in an antitrust investigation
- represented several individuals under investigation for alleged corruption and fraud.
Mr. Paw also lectures frequently on compliance issues bringing lessons learned from his experience in Iraq and in prosecutor offices to his audiences. He also frequently speaks on law enforcement policy issues before public forums and in the media.
Mr. Paw also has been active with the Fund for Peace, a nonprofit group in Washington that works to promote sustainable security and produces the Failed States Index, an annual ranking of countries across several indicators, published by Foreign Policy magazine.
Mr. Paw was the director of New Jersey’s Division of Criminal Justice, in the Office of the Attorney General, from February 2006 until June 2008. There, he led the statewide office responsible for enforcing New Jersey’s criminal laws and supervised more than 800 lawyers, investigators and staff in the investigation of complex criminal cases involving corruption, fraud, money laundering, health care fraud and financial crimes.
Before that, he was a prosecutor for nine years with the United States Attorney’s Office for the Eastern District of Pennsylvania and was Deputy U.S. Attorney from 2005 until 2006. He also served with the U.S. Justice Department from 2004 to 2005 as an advisor to the Iraqi government on criminal cases against Saddam Hussein and other former senior regime members. He has tried many criminal cases and supervised numerous government investigations.
From 1992 to 1993, Mr. Paw served as associate counsel to the U.S. House of Representatives’ Foreign Affairs Committee, reviewing allegations concerning American hostages held in Iran in 1980.
