Warren T. Allen II

Warren T. Allen II conducts internal investigations and reviews for companies and their boards in matters involving the Foreign Corrupt Practices Act, the Securities Exchange Act, the Commodity Exchange Act, and other statutes and regulations. He also assists in investigations of sensitive personal matters and represents companies and individuals in enforcement actions and civil litigation. Mr. Allen draws on his twelve years of prior experience at Skadden, Arps, Slate, Meagher, & Flom LLP to craft creative solutions to clients’ problems. Prior to attending law school at Georgetown, Mr. Allen served for six years as a police officer, including an assignment to the detective bureau. After graduating from Georgetown, he clerked for the Honorable Gladys Kessler at the U.S. District Court for the District of Columbia where he helped draft opinions and orders on matters involving employment discrimination, retaliation, contract disputes, fraud, the Racketeer Influenced and Corrupt Organizations Act, and the Administrative Procedure Act.

Representative Investigative and Enforcement Matters

  • Investigated corruption allegations on behalf of multinational firms, including investigations involving Angola, Argentina, Brazil, China, Iraq, Mexico, Portugal, Romania, Russia, Saudi Arabia, Serbia, Spain, Taiwan, Thailand, Turkey, and several other jurisdictions
  • Investigated allegations of patient abuse on behalf of a hospital
  • Investigated alleged violations of International Traffic in Arms Regulations in Saudi Arabia
  • Investigated alleged violations of anti-terrorism laws on behalf of a global conglomerate
  • Conducted an internal investigation on behalf of a bank in connection with an inquiry by the U.S. Commodity Futures Trading Commission into derivative benchmark rate manipulation
  • Conducted an internal investigation on behalf of a bank in connection with an insider trading inquiry by the U.S. Securities and Exchange Commission
  • Conducted an investigation on behalf of the Council of the District of Columbia of then-D.C. Councilmember Marion Barry’s contract and grant award practices

Representative Litigation Matters

  • Represented a former president of a foreign state before the U.S. Supreme Court, the U.S. Court of Appeals for the D.C. Circuit, and the U.S. District Court for the District of Columbia in connection with an immunity claim
  • Represented clients in securities fraud class actions
  • 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 independent directors of a company in a bankruptcy adversarial proceeding involving claims of breached fiduciary duties
  • Represented a member of the “Norfolk Four” in habeas corpus proceedings and related civil rights matters

Representative Compliance and Diligence Matters

  • Led anti-corruption diligence efforts for multiple companies in several transactions, including a $6 billion technology company acquisition, a $173 million food products company acquisition, and a $130 million media company merger
  • Performed global corruption risk assessment and developed anti-corruption policies and related materials for multi-national consumer products company
  • Benchmarked Fortune 50 technology company’s compliance program against best practices in several key risk areas, including anti-corruption, antitrust, internal reporting, corporate governance, and ethics
  • Assisted a bank with assessing whether its products and services created risks of unfair, deceptive or abusive acts or practices
  • Advised a company on reducing risks of money laundering violations to help facilitate a contemplated cross-border funds transfer

Community Service

Mr. Allen currently serves as a member of the boards of directors for the Mid-Atlantic Innocence Project and for the Center for Teaching the Rule of Law.  He also serves as a Senior Fellow for the UCLA Luskin School of Public Affairs.  Mr. Allen previously served on the board of directors for the Washington Literacy Center, as a Trustee for the Washington Lawyers’ Committee for Civil Rights and Urban Affairs, and as a member of the Legal Services Corporation’s Emerging Leaders Council. Mr. Allen received the Klepper Prize for Volunteer Excellence from the Legal Aid Society of the District of Columbia for pro bono work on behalf of domestic violence survivors.

Selected Publications and Panels

  • Panel, “Chief Audit Executives and In-House Counsel,” the Government Investigations & Civil Litigation Institute, Eighth Annual Meeting (November 2022)
  • How Lawyers Can Leverage the Shifting Environment to Enhance Compliance Programs, Anti-Corruption Report (August 2022)
  • COVID-19: How to Mitigate Compliance Risk Amid a Crisis (April 2020)
  • DOJ Announces Revisions to Yates Memorandum Policy (December 2018)
  • Major Recent FCPA Developments and Their Implications, Global Investigations Review (February 2018)
  • Multi-Jurisdictional Anti-Corruption Investigation and Enforcement Trends and Developments, The Review of Securities & Commodities Regulation (October 2018)
  • Panel, “The Anatomy of a Multi-Jurisdictional Anti-Corruption Enforcement Action: What Multinational Companies and Their Advisors Need to Know About the Evolving Landscape,” American Conference Institute’s 9th Global Forum on Anti-Corruption Compliance in High-Risk Markets (July 2018)
  • Panel, “Compliance Innovations & Best Practices for Responding to Global ABAC Challenges,” the 11th Annual A.C.E.S. Compliance Summit, Anti-Corruption, Export Controls, and Sanctions (April 2018)
  • Revised FCPA Corporate Enforcement Policy, Harvard Law School Forum on Corporate Governance and Financial Regulation (December 2017)

Education

J.D., Georgetown University Law Center, 2006 (cum laude; Senior Articles Editor, Georgetown Journal of Law & Public Policy) M.P.P., University of California, Los Angeles, 2003 (highest honors) B.A., University of California, Los Angeles, 1999

Bar Admissions

Federal U.S. Supreme Court U.S. Court of Appeals for the District of Columbia Circuit U.S. District Courts for the District of Columbia and the Eastern District of Virginia U.S. Bankruptcy Court for the Eastern District of Virginia State District of Columbia Commonwealth of Virginia Maryland