• Jacqueline C. Wolff

    Co-Chair, Corporate Investigations and White Collar Defense
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    New York
    Direct: 212.790.4620
    General: 212.790.4500
    Fax: 212.790.4545


    Fordham University School of Law, J.D
    Dean’s List with Distinction, Fordham Law Review


    University of Pennsylvania, B.A., Biology/Sociology

    French and German
    Bar Admissions
    New York
    • Profile
    • Representative Matters
    • Honors & Awards
    • Publications
    • Memberships & Activities
    • Speaking Engagements


    Jacqueline Wolff has spent over 25 years defending companies and individuals accused of white collar crimes and False Claims Act (FCA) violations. A former Chief of the Environmental Crimes Unit and Assistant United States Attorney for the Frauds Division in the District of New Jersey, Ms. Wolff focuses her practice on violations of the Foreign Corrupt Practices Act (FCPA), and fraud based crimes including healthcare, securities and tax fraud, mostly in the healthcare, pharmaceutical and financial services industries. She has successfully defended multiple clients in False Claims Act cases resulting in declinations from the government, resolutions as overpayment cases or, where the government decided not to intervene, outright dismissals of the qui tam. She has also represented corporate clients ranging from Fortune 100 companies to small venture capital firms in FCPA investigations. Ms. Wolff has successfully represented corporate officers in tax and securities fraud matters.

    While in the United States Attorney’s Office, Ms. Wolff received numerous awards, including those from the U.S. Nuclear Regulatory Commission, Immigration and Naturalization Service, Environmental Protection Agency and the Attorney General of the United States.

    Ms. Wolff regularly is sought out by business publications and CLE sponsors to speak on FCPA and FCA issues.

    Representative Matters

    • Successfully represented a multinational company in an FCPA investigation involving the President of an African country.
    • Successfully represented a hospital system in an FCA investigation by a US Attorney resulting in a declination
    • Successfully represented a pharmaceutical company in a False Claims Act Qui Tam resulting in dismissal of the case.
    • Successfully represented a clinical laboratory company in a False Claims Act investigation by a US Attorney resulting in a negotiated overpayment settlement
    • Representation of a Fortune 100 company in Department of Justice and SEC investigation into alleged FCPA violations resulting in an NPA for the parent company.
    • Successfully defended a construction company in an immigration investigation by ICE and the Department of Justice resulting in an NPA.
    • Representation of a large pharmaceutical company in a Department of Justice and OIG investigation relating to sales and marketing practices and concluding in a DPA.
    • Successfully defended officers of an international investment advisor in SEC investigation into securities fraud.
    • Successfully represented officers of a multinational oil drilling corporation in Department of Justice and SEC investigation into FCPA violations.
    • Currently representing a bank officer in the current Swiss bank investigations by the Department of Justice.
    • Currently representing individuals in the Libor and Fx Trading investigations
    • Conducted an internal investigation into a pharmaceutical company's interactions with physicians and designed a compliance program to address weaknesses in internal controls.
    • Assisted dozens of multinational companies in conducting due diligence into potential FCPA and global anti-corruption violations by target companies and advised on the intended acquisitions.
    • Designed FCPA and global anti-corruption compliance programs for multinational entities and private equity and venture capital firms doing business in, among other countries, Russia, India, the U.K. and China.

    Honors & Awards

    Bronze Medal, U.S. Environmental Protection Agency.

    Special Commendation, Attorney General of the United States.

    New York Super Lawyers, 2007–2015.


    Co-author, “FCPA and AML Enforcement Review — ‘Follow the Money’: Liberty Reserve Case,” Payments Compliance, March 2, 2016.

    Quoted, “Lack of Training and Due Diligence Leads to $19 Million Penalty for Hitachi,” The FCPA Report, October 7, 2015.

    Quoted, “When and How Should Companies Include Audit Rights in Third-Party Contracts?” The FCPA Report, August 20, 2014.

    Quoted, “When and How Should Companies Include Audit Rights in Third-Party Contracts?” The FCPA Report, August 6, 2014.

    Quoted, “A Guide to Anti-Corruption Representations in Third-Party Contracts: Clauses for High-Risk Situations and Enforcement Strategies,” The FCPA Report, July 9, 2014.

    Co-author, “General Schemes vs. Specific Claims: The Ongoing Circuit Split over Fraud and the False Claims Act,” Law Journal Newsletters Business Crimes Bulletin, July, 2014.

    Author, “General Schemes vs. Specific Claims; The Ongoing Circuit Split over Fraud and the False Claims Act,” Business Crimes Bulletin, July 1, 2014.

    Interviewee, “FCPA Training That Works: An Interview with Jacqueline C. Wolff,” The FCPA Report, May 2013.

    Co-Author, “The New FCPA Guidance: DOJ and SEC's Views on Hospitality, Instrumentalities, Successor Liability, and Compliance,” Manatt Corporate Investigations Newsletter, November 2012.

    Co-Author, “DOJ Escalates Use of the Foreign Corrupt Practices Act To Seize Customer Bank Accounts”, BankNews, October 2012.

    Co-Author, "Is Anyone Not a Foreign Official Under the FCPA?" Business Crimes Bulletin, February 2011.

    Co-Author, "Health Care Reform, or 'Qui Tams Made Easy,'" Business Crimes Bulletin, June 2010.

    Co-Author, "Law Firm Files: When the 'Client' Demanding Them Is Not the Client Who Hired You," Business Crimes Bulletin, October 2009.

    Co-Author, "FCPA Due Diligence and Data Privacy Laws," Business Crimes Bulletin, November 2008.

    Co-Author, "Deferred Prosecution Agreements and Privileged Documents," Business Crimes Bulletin, November 2007.

    Co-Author, "Liability Under the Foreign Corrupt Practices Act," The Review of Securities & Commodities Regulation, January 2007.

    Co-Author, "Liability of U.S. Companies for Alleged Bribery by Foreign Subsidiaries," Law Journal Newsletters, August 2005.

    Memberships & Activities

    Admitted to practice in the state of New York.

    Member, Advisory Board, Bloomberg BNA's Pharmaceutical Law & Industry Report.

    Member, Board of Directors, New York Council of Defense Lawyers.

    Member, Board of Editors, Business Crimes Bulletin.

    Member, Criminal Law Committee, Association of the Bar of the City of New York.

    Member, National Association of Criminal Defense Lawyers.

    Member, New York Women’s Criminal Defense Group.

    Member, Law360 White Collar Editorial Advisory Board.

    Speaking Engagements

    Speaker, “FCPA: Testing Your Compliance Plan Proactively,” Global Secure Summit Dining Club, June 12, 2014.

    Speaker, “Minimizing FCPA Risk Exposure in Majority, Minority and Contractual Joint Ventures”, American Conference Institute’s 30th National Conference On The Foreign Corrupt Practices Act, May 2014.

    Speaker, “Minimizing FCPA Risk Exposure in Majority, Minority and Contractual Joint Ventures”, American Conference Institute’s 29th National Conference On The Foreign Corrupt Practices Act, April 2013.

    Speaker, “Creating a Home for the Whistleblower: How to Facilitate Open Communication and Appropriately Respond to Allegations in a Bounty Hunter Environment,” 28th National Conference on Foreign Corrupt Policy Act, November 15, 2012, Washington, D.C.

    Speaker, “Corporate Internal Investigations: Nuts, Bolts and Special Problems, including the Attorney-Client Privilege,” Rutgers School of Law, September 2012.

    Speaker, "FCPA: Hot Topics in Enforcement, Trends and Compliance Expectations," National Association of Women Lawyers 7th Annual General Counsel Institute, New York, NY, November 3–4, 2011.

    Speaker, "Developing Internal Controls to Manage & Monitor Interactions with Health Care Practitioners & Regulators at All Levels of the Organization," Marcus Evans Life Sciences Strategies for Anti-Corruption & FCPA Compliance Conference, June 22–24, 2011.

    Speaker, "Blowing the Whistle: How the SEC’s Plan Might Play Out," Institutional Investor Legal Forum Winter Roundtable, New York, NY, February 1, 2011.

    Interview, "How to Size Up, and Manage, FCPA Investigation Costs," Compliance Week, August 17, 2010.

    Speaker, "Clinical Trials: Minimizing Potential FCPA Risks When Conducting Global Trials Conference," FCPA and International Anti-Corruption for the Pharmaceutical and Medical Device Industries, New York, NY, April 28, 2009.

    Speaker, "Voluntary Disclosures: Criteria to Determine When to Disclose, or Not," American Conference Institute’s National Conference on the Foreign Corrupt Practices Act, Washington, D.C., November 19, 2008.

    Speaker, "Privacy and Ethical Issues in Internal Investigations," ACI Conducting & Responding to Investigations Conference, New York, NY, April 24, 2007.

    Speaker, "BMS: A Case Study," ACI Corporate Governance Conference, New York, NY, January 19, 2006.