Gary A. Rubin

Gary A. Rubin represents individuals and companies in parallel proceedings involving internal investigations and enforcement proceedings by U.S. and overseas agencies relating to anti-corruption, antitrust, commodities, and securities laws. Many of Mr. Rubin’s representations are multi-jurisdictional, and he frequently addresses conflicts of law involving blocking, data protection, labor, privilege, and secrecy laws. Mr. Rubin also advises clients on anti-corruption and money laundering compliance issues, and assists U.S. and foreign companies in structuring and implementing compliance programs. In addition, Mr. Rubin represents companies and individuals in complex civil litigation, including multi-district litigation, in both state and federal courts. He advises on conducting electronic discovery and on managing electronic data to maximize litigation readiness. Prior to joining WTAII, Mr. Rubin spent seventeen years with Skadden, Arps, Slate, Meagher & Flom LLP where he focused on litigation and investigations matters, first in the Wilmington, Delaware, office and then in the Washington, D.C., office. He was most recently an independent outside consultant to the in-house litigation group of a global financial services company.

Mr. Rubin works remotely from Dallas, Texas.


Representative Investigative and Enforcement Matters

  • Represented United Kingdom-based swap dealer in parallel price manipulation investigations by the U.S. Commodity Futures Trading Commission (CFTC) and the U.S. Department of Justice (DOJ), and a follow-on investigation by the Financial Industry Regulatory Authority, related to the benchmark for valuing cash-settled interest-rate swap options
  • Represented Eurasian telecommunications company in parallel Foreign Corrupt Practices Act (FCPA) investigations by the DOJ and the U.S. Securities and Exchange Commission (SEC) related to conduct in Asia
  • Represented European automaker in parallel FCPA investigations by the DOJ and the SEC related to conduct in Africa, Asia, Europe, and North and South America
  • Represented U.S.-based medical device manufacturer in parallel FCPA investigations by the DOJ and the SEC related to conduct in Asia, Europe, and Central America
  • Conducted internal investigation of medical device company related to allegations of earnings management
  • Conducted internal investigation of tactical communications company related to allegations of misuse of corporate assets by a senior executive
  • Conducted internal investigation on behalf of mining company related to conduct in China

Representative Litigation

  • Obtained partial summary judgment for a financial services company in class action litigation related to benchmarks and derivative financial instruments following government enforcement proceedings
  • Obtained summary judgment for a real estate investment trust in a $22 million fraud and fiduciary duty suit against a broker
  • Obtained summary judgment for a class of real estate investors in a wrongful-takings case against the State of Maryland
  • Represented Canada-based financial institution in contract litigation against a U.S.-based hedge fund regarding a loan securitized in part by the proceeds of single-name credit-default swaps
  • Represented European financial institution in a litigated bankruptcy court adversary proceeding against debtors and the official committee of unsecured creditors in jointly administered cases
  • Represented registered investment adviser in litigation against former members of investment adviser in related proceedings in multiple courts
  • Represented contract market and clearing organization in administrative review litigation against the CFTC related to Dodd–Frank rulemaking

Representative Compliance and Diligence Matters

  • Advised numerous companies in the aerospace, apparel, asset management, automotive, beverage, energy, electronics, environmental, healthcare, mining, technology, and tobacco industries on anti-corruption compliance, including designing and implementing anti-corruption compliance policies and programs
  • Conducted anti-corruption due diligence and remediation in connection with mergers, acquisitions, and financings for merging and acquiring companies, for underwriters, and for creditors in the consumer products, electronics, financial services, healthcare, mining, and technology industries

Selected Publications

  • The Challenges for CEA Price Manipulation Plaintiffs, Law360, April 2017
  • U.S.A. chapter of The International Comparative Legal Guide to Business Crime 2017, Global Legal Group, October 2016
  • Chapter X of Crisis Management in Litigation and Investigations: Parallel Proceedings, Competing Stakeholders, and Multiple Venues, Association of Corporate Counsel, August 2008


J.D., University of Chicago Law School, 1999
M.A., Johns Hopkins University, 1996
B.A., Johns Hopkins University, 1996 (Phi Beta Kappa, Omicron Delta Kappa, Golden Key National Honour Society, general and departmental honors)

Bar Admissions

United States Court of Appeals for the Third Circuit
United States District Court for the Northern District of Texas
United States District Court for the District of Columbia
United States District Court for the District of Delaware

District of Columbia
Delaware (inactive)
Maryland (inactive)


Direct: 214-764-9807
Mail: P.O. Box 601645, Dallas, Texas 75360