Dave helps sophisticated clients manage their government investigations, whistleblower allegations, and global compliance obligations in a practical way in a wide variety of industries, including life-sciences.
He helps them build and assess their compliance programs in light of their business model and risk profile. He helps them respond credibly and proportionately to internal allegations of misconduct through internal investigations. And he helps them respond effectively to government investigations by achieving resolution prior to charges ever being lodged, and by defending them vigorously in enforcement proceedings.
Dave offers the unique perspective of a seasoned lawyer with more than two decades of experience as a senior compliance executive with two global companies, as a federal prosecutor with the U.S. Department of Justice, and as law-firm partner representing corporate boards, public and private companies, and senior corporate executives. He has more than a decade of experience in matters involving the Foreign Corrupt Practices Act, U.S. healthcare fraud & abuse regulation, and False Claims Act litigation, among other areas of criminal and civil law enforcement.
Dave’s clients value his pragmatic and engaging approach that delivers practical advice and effective strategies tailored to their industries, business models and risk.
Compliance Counseling, Program Reviews and Risk Assessments.
Dave helps businesses in a variety of industries ensure that they have cost-effective and practical compliance programs designed to prevent and detect compliance issues before they become systemic.
With eight years of in-house experience, Dave is skilled at program design and governance, resource allocation and staffing, effective use of compliance committees, development and implementation of policies and procedures, compliance education programs, program and risk assessments, compliance program monitoring and auditing, investigation programs, and M&A and JV compliance due diligence.
Dave has managed and performed scores of global compliance program assessments through a mix of qualitative and forensic techniques, reporting to management and boards on the relative strengths, challenges, and opportunities of their programs. Several of these have included “pre-monitorship” assessments that evaluate and enhance programs in anticipation of government scrutiny or imposition of a monitor.
His experience includes the pharmaceutical, medical device, hospital supply, hospice, manufacturing, technology, insurance, transportation, energy, and retail sales industries.
Dave advises companies on how to assess and respond appropriately and proportionately to allegations of misconduct by whistleblowers, either partnering with them to perform the investigation, or performing an independent investigation. These issues have spanned healthcare fraud and abuse, FDA misbranding ("off-label" sales), anti-corruption (FCPA and the U.K. Bribery Act), commercial and financial fraud, embezzlement, export control and sanctions matters, and serious conflicts of interest. He has performed scores of investigations throughout North America, South America, Asia, the Middle East and Europe.
With two decades of investigative experience, Dave has broad perspective and in-house savvy in planning and executing complex, sensitive internal investigations and reporting to senior management, Compliance Committees, and Board level.
Dave helps companies respond appropriately to government inquiries made through civil and criminal investigative demands and subpoenas, and aggressively defends against civil and criminal government enforcement actions. His practice encompasses healthcare fraud and abuse, FDA misbranding ("off-label" sales), corruption (FCPA and the U.K. Bribery Act), commercial and financial fraud, embezzlement, and export control and sanctions matters.