Paul Alfieri is a Partner in the Litigation and Government Investigations practice focusing on white-collar criminal defense, government regulatory matters, internal corporate investigations, and complex civil litigation. He has more than 30 years of high-profile trial, litigation and investigations experience at Am Law 100 firms.  

Mr. Alfieri represents and advises a wide range of clients, from Fortune 100 and Fortune Global 500 public and private companies to Boards, Audit Committees, and senior executives, in investigations relating to foreign corrupt practices/sanctions (including due diligence), securities and accounting fraud, benchmark and foreign exchange manipulations, and price fixing/antitrust.  

Mr. Alfieri was lead counsel on one of the largest price fixing cases ever litigated and has extensive experience representing corporate defendants in a variety of civil matters, including shareholder securities and derivative suits, antitrust class actions and False Claims Act cases. 

Representative Experience

Anti-Corruption and Anti-Bribery 

  • Represented a global manufacturing company regarding allegations of violations of the Foreign Corrupt Practices Act (FCPA) at the company’s subsidiaries in China and in other high-risk jurisdictions in Latin America, Eastern Europe, and the Middle East and a favorable settlement with the Securities and Exchange Commission (SEC) (the  U.S. Department of Justice (DOJ) took no action). 
  • Represented a multi-national water technology company in connection with an FCPA investigation into its South Korean subsidiary in which the DOJ and SEC took no action against the company. 
  • Counseled multiple banks/underwriters and public companies in anti-corruption/sanctions-related due diligence in connection with securities offerings. 
  • Advised a senior executive at a European energy company in connection with a DOJ and SEC investigation into alleged payments to Nigerian government officials for the purchase of an offshore oil lease. 
  • Represented the CEO and other senior executives of a German-based motor vehicle corporation in a FCPA investigation conducted by the DOJ and SEC. 
  • Counseled a former naval officer in the “Fat Leonard” bribery investigation being conducted by the DOJ. 
  •  Advised a U.S.-based consumer company in an FCPA due diligence investigation in a high-risk jurisdiction in Eastern Europe. 
  • Counsel to various public companies in the review of their anti-corruption/compliance policies, procedures, and systems. 

Securities and Accounting Fraud 

  • Represented Royal Ahold and its U.S. subsidiaries, including Stop & Shop and U.S. Foodservice, in the investigation and resolutions with the DOJ and SEC in connection with allegations of accounting and securities fraud which required a restatement of almost $1 billion in which the company paid no monetary penalty. 
  • Advised an Audit Committee of a publicly traded technology company in an investigation conducted by the SEC in which no action was taken against the company or any of its executives. 
  • Counsel to an accounting firm in an SEC investigation/enforcement action relating to the alleged overvaluing of mineral assets by a global mining company. 
  • Represented the former CEO of a Mexican construction company in an SEC enforcement action relating to the alleged inflation of home sales. 
  • Provided counsel to various public companies and financial institutions in shareholder class actions and derivative suits. 

Financial Services 

  • Represented a U.S.-based financial institution in an internal investigation and follow-on FINRA investigation into allegations of insider trading and self-dealing in which no action was taken against the bank. 
  • Counsel to a number of executives at a global bank in an investigation conducted by the DOJ into the manipulation of foreign exchange rates and “front running.” 
  • Advised an executive at a major U.S.-based bank in respect to a DOJ and Commodity Futures Trading Commission investigation into the manipulation of ISDAFIX rates. 
  • Led the legal team advising senior executives at a U.S.-based bank in various investigations relating to the manipulation of LIBOR 
  • Represented a U.S.-based financial institution in an internal investigation relating to pricing issues with its advertising agency. 
  • Advised a global financial institution in various shareholder class actions relating to the collapse of Enron in which the case was dismissed before trial. 
  • Represented a global financial institution in a shareholder class action stemming from the financial crisis in which the case was dismissed on a motion to dismiss. 

Antitrust/Price Fixing 

  • Represented The Yokohama Rubber Company Ltd. in an investigation by the DOJ and numerous other competition authorities around the world in a global price fixing cartel involving marine hose and the related civil class action. 
  • Counsel to a non-U.S. manufacturing company in a DOJ investigation into alleged price fixing in the auto parts industry. 
  • Advised Takeda Pharmaceutical Company in the Vitamins Antitrust class action, one of the largest price fixing cases ever litigated, which was settled prior to trial on terms favorable to the company. 

Political Corruption 

  • Counsel to a key cooperating witness in the political corruption trial and retrial conducted by the DOJ of former New York Senate Majority Leader Dean Skelos and his son. 
  • Led the legal team for a multi-national construction company in an internal investigation into alleged billing and minority business fraud and the follow-on investigations conducted by the DOJ and the Manhattan District Attorney's Office. 
  • Represented a medical malpractice insurance company in a New York State Joint Commission on Public Ethics (JCOPE) probe into a potential violation of the New York State Lobbying Act for providing an alleged gift to a public official. 
  • Counsel to a campaign contributor in an investigation conducted by the DOJ into the fundraising activities of the New York City Mayor. 

Other Significant Matters 

  • Advised multiple companies in civil False Claims Act investigations conducted by the DOJ and various state Attorneys General’s offices. 
  • Represented a large U.S. insurance brokerage company in an internal investigation stemming from numerous regulatory investigations into the insurance industry. 
  • Counsel to a global commercial real estate company in an internal investigation into potential OFAC and money laundering violations. 
  • Advised a property and casualty insurer in various environmental coverage actions filed in federal and state courts across the country. 

Publications and Speeches

"U.S. Court of Appeals Provides Long- Awaited Guidance Regarding Whether an Entity Should be Considered an ‘Instrumentality’ of a Foreign Government under the FCPA," Reed Smith Client Alerts, 2014 

"Private Equity and the FCPA," Alternative Investment Law Report (BNA), 2014 

"Stock Option Concerns Put Counsels in Spotlight,” New York Law Journal, 2006 

Navigating the U.S. Regulatory Environment – Antitrust and Anti- Corruption, Speaker, Tokyo, Japan, 2014 

PWC Annual Securities Litigation Review, Speaker, New York, New York, 2011 

Memberships and Affiliations

New York City Bar Association

News, Events & Insights


New York University School of Law, J.D. 

Tufts University, B.A. 

  • summa cum laude 
  • Phi Beta Kappa 

Previous Experience

Reed Smith LLP, Partner

Linklaters LLP, Partner

White & Case LLP, Partner


  • New York 
  • U.S. Court of Appeals for the 3rd Circuit  
  • U.S. District Court for the Eastern District of New York 
  • U.S. District Court for the Southern District of New York 

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