• 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 20 years defending companies and individuals accused of a wide array of white collar crimes. A former Chief of the Environmental Crimes Unit and Assistant United States Attorney for the District of New Jersey, Ms. Wolff focuses her practice on violations of the Foreign Corrupt Practices Act (FCPA), healthcare fraud, securities fraud, Food, Drug & Cosmetic Act (FDCA) violations, tax crimes, corporate immigration crimes and other regulatory-based violations. For years she has successfully defended her clients, from a Fortune 100 company being investigated by the SEC for false financial filings to an individual being investigated by the Department of Justice for tax crimes. Ms. Wolff’s experience as both a prosecutor and defense lawyer has provided her with the depth and understanding to assist companies in designing compliance programs to address FCPA and global anti-corruption issues. She has designed FCPA compliance programs for companies in industries as diverse as those in media, pharmaceuticals, sports, green technology and telecommunications.

    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, criminal immigration and FDCA issues. She has written extensively on various criminal defense topics and, in particular, FCPA compliance.

    Representative Matters

    • Currently representing a federal contractor in a US Department of Defense Office of the Inspector General country of origin investigation.
    • Currently representing a multinational company in a corruption investigation involving the President of an African country.
    • Currently representing a bank officer in the Swiss tax investigation by Department of Justice.
    • Currently representing a hospital system in an FCA investigation by Department of Justice.
    • Successfully represented a pharmaceutical company in a False Claims Act Qui Tam resulting in dismissal of the case.
    • Represented an executive of an international liquor distributor charged with tax crimes resulting in a sentence of probation.
    • Representation of a Fortune 100 company in Department of Justice and SEC investigation into alleged FCPA violations.
    • Successfully defended a major service provider in an immigration investigation by ICE and the Department of Justice.
    • Representation of a large pharmaceutical company in a Department of Justice and HHS investigation relating to sales and marketing practices and concluding in a DPA.
    • Conducted an internal investigation into a pharmaceutical company's interactions with physicians and designed a compliance program to address weaknesses in internal controls.
    • Successfully defended officers of an international investment advisor in SEC investigation into securities fraud.
    • Assisted a multinational company in conducting due diligence into potential FCPA and global anti-corruption violations by target company.
    • Successfully represented officers of a multinational oil drilling corporation in Department of Justice and SEC investigation into FCPA violations.
    • Designed FCPA and global anti-corruption compliance programs for multinational entities and private equity 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, 2007–2011.


    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.

    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.