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About Phil

Phil Bezanson helps clients navigate some of the most complicated litigation, regulatory, enforcement and incident response challenges. He primarily represents companies, senior management and boards of directors as well as individuals in internal investigations, regulatory enforcement, criminal defense, and related civil litigation. He has worked on a number of recent high-profile and complex cases, including the Deepwater Horizon explosion, the George Washington Bridge lane closure, General Motors ignition switch investigations, "Pay to Play" cases in New York, New Mexico and Illinois, stock options backdating cases, and a variety of matters involving the Foreign Corrupt Practices Act.

Phil regularly conducts internal investigations and defends corporations and executives facing allegations of securities fraud, antitrust violations, environmental crimes, bribery, insider trading, mail/wire fraud, tax offenses and other business crimes or regulatory violations. He also assists national and international corporate clients with a wide variety of compliance matters including anti-bribery and corruption, cybersecurity and data privacy, insider trading and antitrust enforcement practices at publicly traded companies, and trading desks at financial institutions. Phil has been successful in convincing prosecutors and regulators to abandon investigations before charges are filed. He counsels clients through each step in the defense process, from creating and auditing robust, specifically-tailored compliance programs, guiding clients through unexpected financial, environmental and cyber-related incidents, to preparing clients and their employees to meet with prosecutors or regulatory agencies, to making decisions on negotiation, settlement, trial and appeals.

Phil spent nearly ten years working in Bracewell's New York Office before he moved to the Pacific Northwest, where he is managing partner of Bracewell's Seattle Office.

Experience

Recent Notable Matters

Major retail company — successfully represented a major retail company in connection with an SEC investigation into various public disclosures. The matter was closed by the SEC.

Major retail company — successfully represented a major retail company in connection with a FINRA investigation regarding employee stock trading and the company’s earnings announcements

Various energy sector companies — internal investigations in connection with alleged FCPA violations in Latin America, Africa and the Middle East

Various energy sector companies — responding to cyber-attacks involving business email compromise schemes and other data breaches

Venture capital firm and its principal — SEC investigation concerning disclosures to investors and valuation of assets

Publicly traded technology company — internal investigation in connection with alleged OFAC violations

Leading oilfield services company — federal criminal investigation that arose from the Deepwater Horizon explosion

Independent oil and gas company — federal criminal investigation that arose from a workplace explosion

Major petroleum refinery company — representation in connection with various Renewable Identification Number biofuel investigation

Major retail company — design and implementation of a global anti-bribery and corruption policy

International energy company — design and implementation of a global anti-bribery and corruption policy

Multiple private investment funds and individuals — pay-to-play investigations conducted by the Department of Justice, the New York State Attorney General's Office and the SEC, and related civil litigations

Fortune 200 company — stock options backdating inquiries resulting in no criminal charges and no monetary penalties

International tobacco company — nationwide antitrust litigation and related criminal charges resulting in dismissal of indictment

International aviation company — criminal antitrust investigation

Head of the auction rate securities desk at a financial institution — Successfully extinguished a Wells Notice in connection with an SEC auction rate securities investigation

Multiple chief financial officers of public companies — investigations for accounting fraud and manipulation of financial statements and SEC filings

Fortune 500 chief financial officer — represented during investigation for backdating stock options

High-level General Motors engineering executive — DOJ ignition switch investigation

Former staffer for Governor Chris Christie — George Washington Bridge closure investigation, and a different former staffer and a former executive of the Port Authority of New York and New Jersey in a federal criminal trial

Publications and Speeches

“Government Investigations and Technology: Innovation and Preparation,” Society of Corporate Compliance and Ethics, November 17, 2017.

“Criminal Investigations and Technology: Protecting Data and Rights,” Washington Association of Corporate Counsel Tech Summit, June 8, 2017.

"Tech Rally - Industry Giants Back Google's Play to Protect Data," Corporate Compliance Insights, March 15, 2017.

“How to Minimize Your Company’s Legal Exposure From Data Breaches,” Oil & Gas Financial Journal, February 20, 2017.

"In Salman, Supreme Court Rejects Higher Evidentiary Burden on Prosecutors in Insider Trading Cases," Inside Counsel, January 9, 2017.

“Attorney-Client Privilege in WA No Longer Applies When Employment Ends,” Corporate Compliance Insights, December 20, 2016.

“Recent Cases Every In-House Counsel Should Know About,” Washington State Bar Association, October 28, 2016.

“Seven Tips for Preparing Associates for Trial,” NWSidebar, September 6, 2016.

"Government Reach Does Not Extend to Information Stored Overseas," Corporate Compliance Insights, August 8, 2016.

“Avoiding the Pitfalls: Ethical Issues for In-House Lawyers – the GM Ignition Switch Case Study,” Washington ACC, July 14, 2016.

"DOJ Announces First Declinations After Implementing FCPA Pilot Program," Corporate Compliance Insights, June 22, 2016.

"Vimpelcom's Global FCPA Settlement: A Multinational Resolution," Corporate Compliance Insights, June 17, 2016.

“The Criminalization of Process Safety,” Inside Counsel, March 15, 2016.

“FCPA Year in Review” Momentum Webinar Series, January 21, 2016.

"Combating Fraud at Home and Abroad," Oil & Gas Monitor, December 23, 2015.

“Strengthening the Audit, Legal & Compliance Officer Relationship to Ensure Collaboration Throughout Your Internal Organization” Oil & Gas Anti-Corruption Compliance Exchange, September 22, 2015.

"Preventative Medicine: Internal Investigations Strengthen Compliance Programs and Minimize External Inquiries," Pharmaceutical Compliance Monitor, January 9, 2015.

Credentials

Education

Duke University School of Law,
J.D.
2004
Columbia University,
Bachelor of Arts
2001

Bar Admissions

Washington
New York

News

News

Oil industry rocked by global corruption scandals

February 2, 2018
Toronto Star Online

DOJ Releases New Guidance on Compliance Programs

March 9, 2017
Corporate Compliance Insights

Legal Liability From Cyber Attacks

February 20, 2017
Oil & Gas Financial Journal

Seven Tips for Preparing Associates for Trial

September 8, 2016
Washington State Bar News - Online

Combating Fraud at Home and Abroad

February 26, 2016
Oil & Gas Monitor

Combating Fraud at Home and Abroad

December 23, 2015
Oil & Gas Monitor

Four Risks Pharma Companies Face

August 17, 2015
Pharmaceutical Compliance Monitor

Insights

Insights

Regional Enforcement Snapshot of Southern Africa

March 22, 2016

According to the Transparency International Corruption Perceptions Index for 2014 (hereafter the "International Corruption Index"), the nine countries that make up southern Africa rate from "average" to "corrupt." The South African countries with the worst ratings include Zimbabwe, Madagascar, Malawi, and Zambia. Zimbabwe (21 on the International Corruption Index, with 0 being "highly corrupt" and 100 being "very clean"): President Mugabe's government is considered highly corrupt and inefficient. The labor market is highly restrictive, business licensing is oppressive, and the government...

Regional Enforcement Snapshot: North Africa

May 12, 2015

Attorneys from our white collar, internal investigations and regulatory enforcement team profile recent enforcement actions in the North African states of Morocco, Algeria, Tunisia, Libya, Sudan and Egypt. The report illustrates the need for ongoing caution from investors in the energy sector in the region. Morocco Morocco scored 39 on the Transparency International Corruption Perceptions Index for 2014 (hereafter the "International Corruption Index"), with 0 being "highly corrupt" and 100 being "very clean." US regulators use the International Corruption Index as an indicator for...

Risks and Rewards: Doing Business in Africa and Anti-Bribery Laws

Understanding the risks associated with local corruption, and how to comply with anti-bribery laws such as the UK Bribery Act the US Foreign Corrupt Practices Act ("FCPA"), has become a necessary aspect of doing business internationally. As companies look for opportunities to do business in Africa, the fight against corruption will need to be an integral part of planning new ventures and transactions. With a continent as vast and diverse as Africa, one must be careful about making blanket generalizations about corruption in Africa. For example, using statistics compiled by Transparency...

Noteworthy

Noteworthy

The Legal 500 United States
Corporate Investigations and White Collar Criminal Defense, 2017 - 2018; Litigation: White-Collar Criminal Defense, 2014 - 2015
Thomson Reuters
New York Super Lawyers
Rising Stars, 2014
Duke University School of Law
Law and Technology Review
Managing Editor

Events