Richard Grime

Partner

Richard W. Grime is a partner in O'Melveny's Washington, DC office and a member of our Securities Enforcement and Regulatory Counseling Practice. He represents clients in internal investigations and on a full range of securities enforcement, regulatory, and compliance matters. He routinely represents clients in investigations before FINRA, the Securities and Exchange Commission and other government agencies. He is a frequent speaker at conferences and seminars covering the Foreign Corrupt Practices Act (FCPA) and securities enforcement.

Illustrative Professional Experience

• Representation of a company in an FCPA investigation regarding activities in India, Indonesia and the Middle East
• Representation of a company in an FCPA investigation regarding activities in Turkey and India
• Advising hedge funds, public companies and mutual funds regarding FCPA compliance
• Assisting independent consultant in connection with Securities and Exchange Commission Final Judgment for financial fraud
• Advising private equity firm on insider trading issues
• Representation of broker-dealer in FINRA investigation
• Representation of major bank in auction rate securities investigation before the Securities and Exchange Commission and other government agencies

Before he joined O’Melveny, Richard spent over nine years in the Division of Enforcement at the U.S. Securities and Exchange Commission in Washington, DC. In his last four years at the Commission he was an Assistant Director. While at the SEC, Richard supervised the filing of over 70 enforcement actions covering a wide range of the Commission’s activities.

Some of the more complex and notable cases include:

• A series of FCPA cases including the largest settlement obtained in a parallel enforcement action with the Department of Justice
• Numerous financial fraud cases including the second largest penalty assessed by the Commission for accounting fraud
• Regulated entity cases including:
  • settlement involving the largest assessed penalty against a registered broker-dealer for failure to establish, maintain and enforce written policies designed to prevent insider trading;
  • one of the Commission’s principal cases against a major securities firm for failure to promptly produce email; and
  • the Commission’s only recent cases against foreign transfer agents for failure to register with the Commission
  • Numerous insider trading cases, including one of the Commission's largest cases involving over $10 million in recovered profits and penalties
  • Boiler room, offering frauds and ponzi scheme enforcement actions

While at the SEC, Richard played a prominent role in the Commission’s FCPA program, spoke at FCPA conferences, and participated or supervised many of the Commission’s FCPA cases. He also worked closely with the Department of Justice on countless parallel investigations. Richard was also designated by the United States as one of its experts for the OECD Convention on Combating Bribery of Foreign Public Officials’ peer monitoring process for Japan and Canada.

Prior to working at the Commission, Richard spent ten years in private practice.

Professional Activities

“Discussion of FCPA Compliance Matters,” Bloomberg TV interview by Catherine Yang (May 30, 2008)
“Waiver vs. Protection of Attorney-Client Privilege: Ensuring a Deliberate Approach,” Panelist, American Conference Institute's Sixth National Forum on Conducting, Managing and Responding to Corporate Investigations (May 20, 2008)
“The Foreign Corrupt Practices Act: Developing a Compliance Program,” webcast, sponsored by West Legalworks (May 5, 2008)
• “Practical Guide to the Foreign Corrupt Practices Act,” sponsored by the District of Columbia Bar (May 5, 2008)
• “Identifying and Correcting Books and Records Violations” panel presentation at the FCPA and International Anti-Corruption for Pharma & Life Sciences conference, sponsored by the American Conference Institute (April 29-30, 2008)
• “The Nuts and Bolts of Conducting an Internal Investigation,” panel presentation at the Foreign Corrupt Practices Act 2008: Coping with Heightened Enforcement Risks, sponsored by the Practising Law Institute (April 23, 2008)
• “Voluntary Disclosures: How the Government Evaluates Them and What to Include,” panel presentation at the 19^th National Conference on the Foreign Corrupt Practices Act, sponsored by the American Conference Institute (March 27, 2008)
• “The Foreign Corrupt Practices Act at 30 Years,” panel presentation at the 22^nd Annual National Institute on White Collar Crime, sponsored by the American Bar Association (March 7, 2008)
• “Foreign Corrupt Practices Act Voluntary Disclosures - Strategies to Minimize Penalties, Policies to Avoid Violations,” teleconference presentation, sponsored by Strafford Publications (January 9, 2008)
• “Foreign Corrupt Practices Act In India - Compliance Strategies Given India’s Unique Cultural and Governmental Intricacies,” teleconference presentation, sponsored by Strafford Publications (December 19, 2007)
• “Insider Trading Issues,” panel presentation at the Hedge Fund Enforcement Issues and Regulatory Developments 2007, sponsored by the Practising Law Institute (November 19, 2007)
• “Voluntary Disclosures: How the Government Evaluates Them and What to Include,” panel presentation at the 18^th National Conference on the Foreign Corrupt Practices Act, sponsored by the American Conference Institute (November 13, 2007)
• “Lessons Learned from Recent DOJ and SEC Enforcement Actions,” panel presentation “Doing Business Under the Foreign Corrupt Practices Act,” sponsored by the New York City Bar (November 9, 2007)
• “Roundtable of Hypothetical Cases with Enforcement Officials and Defense Counsel,” panel presentation at The Foreign Corrupt Practices Act: Coping with Heightened Enforcement Risks seminar, sponsored by the Practising Law Institute (September 17, 2007)
  
  Publications
• Obvious and Not-So-Obvious Consequences from the Rise in FCPA Enforcement, co-authored with A. Fischer, 22^nd Annual National Institute on White Collar Crime, ABA-CLE (2008)
• New Issues And Old Tools; How The SEC Is Responding To Insider Trading By Hedge Funds, Hedge Fund Enforcement Issues and Regulatory Developments, Practising Law Institute (2007)
• Voluntary Disclosure -- Evaluating the Benefits and Burdens, co-authored with L. Lunskaya included at the 18^th National Conference Foreign Corrupt Practices Act, sponsored by the American Conference Institute (2007)
• Ramifications of Recent FCPA Enforcement Cases for Compliance Programs, co-authored with G. Lichtenbaum, The Foreign Corrupt Practices Act: Coping with Heightened Enforcement Risks, Practising Law Institute (2007)