Steve Bunnell

Partner

Stevan E. Bunnell is Managing Partner of O’Melveny’s Washington, DC office and a member of the White Collar Defense and Corporate Investigations Practice. His practice focuses on representing corporate and individual clients in civil and criminal matters.

Steve is a highly regarded former prosecutor with over two decades of experience in handling cases involving criminal antitrust, health care fraud, congressional and executive branch corruption, government procurement fraud, corporate and securities fraud, export control violations, violations of the Bank Secrecy Act, and money laundering. He has extensive experience managing international and multi-jurisdictional internal investigations, and defending corporate clients in complex criminal and civil enforcement actions. Steve has been recognized as a leading white collar defense lawyer by Chambers USA; Corporate Counsel; Expert Guides’ Handbook of the World’s Leading White Collar Crime Lawyers; International Who’s Who of Business Crime Lawyers; Best Lawyers in America; and Washington, DC Super Lawyers.

Prior to joining O’Melveny, Steve served as the Chief of the Criminal Division of the U.S. Attorney’s Office for the District of Columbia, where he oversaw the investigation and prosecution of hundreds of federal white collar crime and public corruption cases. He also served as Chief of the U.S. Attorney’s Office’s Fraud and Public Corruption Section, Counsel to the Assistant Attorney General for the Criminal Division, a Trial Attorney in the Department of Justice’s Public Integrity Section, and as an Assistant U.S. Attorney.

Illustrative Professional Experience

• Representation of a federally regulated bank in U.S. Justice Department investigation of alleged criminal violations of the Bank Secrecy Act

• Representation of a former United States Senator in connection with a Justice Department investigation of the firing of United States Attorneys

• Counsel to a leading health insurance company in connection with a U.S. Department of Justice investigation of alleged misconduct by employees and contractors

• Supervised internal investigation and CMS compliance review for a Medicare Advantage health plan in connection with risk adjustment data issues

• Counsel to the Audit Committee of a large multinational corporation in connection with multiple international antitrust investigations

• Counsel for an international airline in an industry-wide U.S. Justice Department criminal antitrust investigation

• Counsel to a multilateral financial institution in connection with an internal investigation of whistleblower allegations of corruption

• Counsel to a major government contractor in connection with a U.S. Justice Department criminal bid rigging investigation

• Representation of a national trade association and its current and former senior officers in connection with a Department of Justice public corruption investigation

• Counsel to a leading health insurance company in connection with high profile False Claim Act litigation

• Counsel for a leading pharmaceutical company in a civil Medicaid fraud case brought by the Texas Attorney General's Office

• Representation of a national agricultural commodity promotion and research program in connection with a U.S. Department of Agriculture inspector general investigation

• Counsel to a large U.S. corporation in connection with a massive breach of private personal data

• Representation of senior executives of multinational corporations in connection with Department of Justice price fixing investigations

• Counsel for individuals, including senior government officials, in connection with Justice Department and U.S. Attorney's Office public corruption, money laundering, and procurement fraud investigations, including the Abramoff investigation and the Iraq and Afghanistan procurement fraud investigations

Professional Experience at the U.S. Attorney's Office and the Justice Department:

• Handled numerous sensitive and complex public corruption investigations, including criminal allegations against high ranking Executive Branch officials, Members of Congress, Assistant U.S. Attorneys, FBI, DEA and other federal law enforcement agents
• Supervised many high-profile matters, including: the prosecution of Riggs Bank for Bank Secrecy Act and other violations; the investigation of ABN/AMRO for BSA and sanctions violations; the prosecution of Mitchell Wade, a defense contractor, for bribery of former Congressman Randall “Duke” Cunningham; investigation of potential criminal violations arising out of accounting practices at Fannie Mae; prosecution of contracting fraud and bribery allegations involving executives of Douglas Development Company and high-ranking officials of the DC Government; prosecution of entrepreneur Walter Anderson for evading more than $250 million in federal taxes; investigations of current and former Members of Congress for potential fraud, bribery, and campaign financing violations; and multiple investigations of multi-million dollar federal procurement fraud involving parallel False Claims Act/Qui Tam proceedings
• Advised the Assistant Attorney General for the Criminal Division on legal, policy and administrative matters
• One of five anti-corruption experts selected by the U.S. Government to evaluate, and recommend improvements to, integrity and anti-corruption programs of Council of Europe members. Conducted field examination of anti-corruption policies and practices of Bosnia and Herzegovina

Professional Activities

Law Clerk, Honorable Laurence H. Silberman, U.S. Court of Appeals, District of Columbia Circuit
Admitted, District of Columbia
Lecturer, Frequent speaker at bar conferences, Justice Department training courses, presentations, and law school classes on issues relating to trial practice and federal prosecution. Recent presentations include:

Corporate Plea Negotiations and Sentencing, National Federal Sentencing Guidelines Conference, Orlando, Florida (May 2011)

Hot Topics in Corporate Internal Investigations, D.C. Bar CLE Presentation, Washington, DC (October 2010)

Corporate Plea Negotiations and Sentencing in a Post Thompson Memo World, National Federal Sentencing Guidelines Conference, St. Petersburg, Florida (May 2010)

Sentencing Practice and Procedure: Plea Negotiations, Charging Practices, Sentencing Tactics, and Victims Rights, ABA Criminal Justice Section's Fall Program, Washington, DC (November 2009)

Assessing and Managing the Risk of U.S. Law Enforcement Actions, O'Melveny/Deloitte Conference on the Re-Regulation of America After the Financial Meltdown: The View of Washington, DC Insiders, Hong Kong (October 2008)

Federal Plea Bargaining, Federal Bar Association and United States Sentencing Commission Annual Conference on the Federal Sentencing Guidelines, Orlando, FL (May 2008)

Federal Law Enforcement Trends, Association of Corporate Counsel, Southern California Chapter, Los Angeles, CA (February 2008)

Law Enforcement Issues in Export Control Investigations, TechNet Export Controls Conference, Santa Clara, CA (January 2008)

Co-Author, In-House Counsel’s Guide to Conducting Internal Investigations (O’Melveny & Myers Handbook, October 2010); New Incentives for Corporations to Maintain Effective Compliance and Ethics Programs (O’Melveny & Myers Client Alert, May 2010); "Start Talking — Or Else," Legal Times (August 2008) (with Meaghan McLaine); Stolt-Nielsen Finally Gets Amnesty (January 2008); Criminal Enforcement of Export Control/Sanctions Laws Announced as Top Priority of Justice Department and Partner Agencies Just as Higher Penalties Authorized (October 2007); Negotiating Justice: Prosecutorial Perspectives on Federal Plea Bargaining in the District of Columbia, 43 American Criminal Law Review 1063 (2006) (with Mary Patrice Brown)

Awards, Named leading lawyer in International Who's Who of Business Crime Lawyers (2010-2011); Named "Top Lawyer" by Corporate Counsel (2010-2011); Named to Expert Guides’ handbook of the “World’s Leading White Collar Crime Lawyers” (2010); Chambers USA (2010-2012); Best Lawyers in America (2009-2012); Department of Justice Special Achievement Awards (1991, 1993, 1996-2001); Attorney General’s Special Commendation Award (1995)
District of Columbia Circuit Representative, United States Sentencing Commission's Practitioners Advisory Group (2011 to present)
Treasurer, Edward Bennett Williams American Inn of Court (1999 to present)
Member, Stanford Law School, Board of Visitors (2008 to present); Executive Board, Assistant United States Attorney Association (2002 to present); the Barristers (2004 to present)
Adjunct Professor of Law, Georgetown University Law Center and George Washington University Law School (2000-2002)
Vice Chair, Steering Committee, Criminal Law and Individual Rights Section, District of Columbia Bar (1996-1999)