People

Overview

Michael Ward is a partner in the Palo Alto office. His practice focuses on assisting senior executives and corporate boards by leading responses to critical enforcement challenges, such as government and internal investigations. He also emphasizes the need for companies to protect shareholder value and senior leaders from enforcement action by taking proactive and practical measures that reduce the likelihood and severity of an enforcement action. His rare background having experience both as a former federal prosecutor and a chief compliance officer enables him to understand and anticipate enforcer perceptions and provide clients with practical and actionable guidance to address those concerns.

Mike has deep enforcement experience having served 16 years as an Assistant United States Attorney for the U.S. Department of Justice in Minneapolis, where he led multiple federal crime investigations, tried over 50 federal criminal jury trials. He supervised the investigation and prosecution of numerous federal crimes, including public corruption, insider trading, money laundering, terrorist financing, bank fraud, currency transaction structuring, price fixing, government contracting frauds and export control violations. After a long career as a federal prosecutor, Mike took a position with Target Corporation where he led the retail company's worldwide internal investigations function including fraud within its global supply chain. He also designed and implemented Target's first corporate compliance program. Mike subsequently moved to McKesson Corporation in San Francisco where he was Director of Ethics & Compliance for the global pharma and healthcare distribution company. Thereafter, Mike has served as Chief Compliance Officer and designed and led award winning compliance programs at a series of leading companies in Silicon Valley including Adobe Systems, Cisco Systems and Juniper Networks.

At Juniper, Mike served as a chief risk and compliance officer for a Silicon Valley-based networking equipment company. Notably, he oversaw a six-year Foreign Corrupt Practices Act investigation that spanned across multiple countries. He also led a worldwide ethics and compliance program, enterprise risk management program, and multiple legal operations teams. Mike is experienced in implementing best practices in corporate compliance programs that demonstrate companies' commitments to fulfilling their legal obligations.

Reflecting both his credibility as a former prosecutor and his hands on operational experience in leading effective compliance programs in the real world, Mike has recently been selected and appointed as an Independent Compliance Monitor for a global internet content platform company where he is responsible for assessing and externally reporting on its compliance program effectiveness.

Mike has been recognized with the National Director's Award for Outstanding Performance in response to his contribution to the U.S. Department of Justice. Mike serves as a board member on both the Bay Area Ethics & Compliance Association (BECA) and the High Tech Compliance Group. Immediately after obtaining his J.D. from George Washington University School of Law, he served as a judicial clerk to the Honorable Oliver Seth, Chief Judge, U.S. Court of Appeals, 10th Circuit.

Admission & Affiliations

  • State Bar of California
  • American Bar Association, White Collar Section
  • California Lawyers Association, Criminal Law Section
  • Instructor, Society of Corporate Compliance & Ethics
  • Board Member: Bay Area Ethics & Compliance Association (BECA)
  • Board Member: High Tech Compliance Group
  • Clerkship: Hon. Oliver Seth, Chief Judge of U.S. Court of Appeals for the Tenth Circuit
  • J.D., George Washington University Law School 1985
  • B.A., Accounting, University of Minnesota 1982

Experience

  • (U.S., China, Russia, India, other) – Coordinated internal investigations and defense of technology company to FCPA investigation of customer travel and entertainment practices and channel partner discount manipulation allegations resulting in declination from U.S. DOJ and civil non-bribery settlement with SEC (In the Matter of Juniper Networks, Inc., Admin. Proc. File No. 3-10307, in the United States of America before the Securities and Exchange Commission)
  • Designed and implemented compliance programs and as CCO oversaw all worldwide internal investigations for companies in technology sector (hardware and software), healthcare and pharma distribution, and retail
  • Retained by Board and CCO of multi-national security services company and government contractor to conduct comprehensive compliance program assessment and substantive risk assessment
  • Retained by General Counsel to perform proactive anti-corruption risk assessment for multi-national food production and distribution company
  • Conducted proactive anti-corruption risk assessment on behalf of a Fortune 100 financial services organization
  • (Taiwan) – Defended technology company in competition law investigation of company’s channel partner deal registration platform
  • Designed and implemented scalable third-party due diligence programs for technology companies, healthcare distribution and multi-national retail company
  • Implemented practical, risk based and scalable third-party gift, travel and entertainment compliance policies and procedures
  • Implemented compliance risk data analytics programs and discount and other transaction due diligence procedures to proactively identify compliance risk

Public Corruption Prosecutions

  • Lead prosecutor in investigation of Minneapolis real estate developer for bribery of elected city officials; including prevailing in challenges to the constitutionality of the federal statute at issue culminating in a 9-0 ruling by the United States Supreme Court (Sabri v. U.S., 541 U.S. 600 (2004))
  • Lead prosecutor in an extended undercover investigation of Minneapolis city government
  • Co-lead prosecutor in the first ever prosecution and conviction of a Minnesota state senator; the case arising out of that senator/attorney’s operation of a “self-insurance” scheme which defrauded an Indian Tribe; this case also involved the conviction of the Chairman and Secretary-Treasurer of the Leech Lake Band of Chippewa Indians in a precedent-setting case affecting tribal sovereign immunity (U.S. v Finn, 919 F. Supp. 1305 (D. Minn. 1995))
  • Lead prosecutor in the subsequent prosecution of the succeeding Secretary-Treasurer and other high-ranking officials of the Leech Lake Band for a “kickback” scheme involving tribal construction projects (U.S. v Michaud, No. 0:98-cr-00251 (D. Minn. Aug. 25, 1999) [Note: date of Judgment])
  • Lead prosecutor in the conviction of the Chief Deputy Sheriff of Carver Country, Minnesota on mail fraud, theft and tax charges arising out of a fraudulent charitable donation and embezzlement scheme (U.S. v Castleberry, No. 97-2972 (8th Cir. Jan. 12, 1998))
  • Lead prosecutor in the conviction at trial of two officials of the Minneapolis Public Housing Authority for their operation of an extortionate bribery scheme to influence the award of low-income public housing units to eligible applicants in exchange for cash bribes (U.S. v Hang, 75 F.3d 1275 (8th Cir. 1996))
  • Lead prosecutor of a U.S. Veterans Affairs contracting official and several construction contractors for their participation in a bribery scheme that influenced the award of minority contract set asides for a series of large federal construction projects at the Minneapolis VA hospital

White Collar Crime

  • Lead prosecutor in the conviction at trial on all counts for insider trading and money laundering of a health insurance company corporate vice president who purchased stock options on the basis of material non-public information concerning a proposed acquisition (U.S. v Mooney, 401 F.3d 940 (8th Cir. 2005))
  • Lead prosecutor of multiple construction contractors involved in a felony price fixing scheme intended to allocate federally funded construction contracts for the “sound proofing” by the FAA of thousands of homes adjacent to the Twin Cities International Airport
  • Lead prosecutor in the prosecution of an international pharmaceutical drug smuggling scheme that utilized a sophisticated “off-shore” money laundering operation in the Turks and Caicos Islands
  • Lead prosecutor in the trial of the Chairman/CEO and his co-founder of an elder care assisted living facility company on mail fraud offenses related to the fraudulent solicitation of investors
  • Lead prosecutor of Japanese physician and intellectual property stolen from a research laboratory of the Mayo Clinic
  • Lead prosecutor in the conviction at trial on arson and fraud charges of the owners of a failing St. Paul business seeking to defraud their insurance company (U.S. v Duke, No. 00-2668 (8th Cir. June 29, 2001))
  • Lead prosecutor in the successful prosecution of a multi-state “identity theft” credit card fraud conspiracy case (U.S. v Smith, 62 F.3d 1073 (8th Cir. 1995))
  • Lead prosecutor in the investigation of perpetrators of a nationwide opal gemstone distribution fraud and multi-million dollar money laundering scheme

Anti-Terrorism

  • Lead prosecutor of a Somali immigrant and Minneapolis resident for conspiring to provide material support to the al Qaeda terrorist organization by traveling to and then attending al Qaeda terrorist training camps in Afghanistan and later providing financial assistance to al Qaeda associates in Pakistan
  • Lead prosecutor of a Lebanese national and Minneapolis resident, who attended and taught in al Qaeda training camps in Afghanistan and fought in jihad both there and in Chechnya, for making false statements concerning his prior associations and assistance to other al Qaeda associates

Violent Crime

  • Lead prosecutor in the conviction at trial of an interstate gun trafficking conspiracy involving an armed gun shop robbery and the execution-style double murder of the two store clerks. This prosecution was recognized with the National Director's Award from Attorney General Janet Reno for outstanding performance as an Assistant United States Attorney (U.S. v Logan, No. 98-2839 (8th Cir. Apr. 24, 2000))
  • Lead prosecutor in the conviction at trial of several gang members responsible for multiple violent bank robberies; this case involved one of the first ever Daubert-admissibility headings on the reliability of PCR DNA evidence (U.S. v Beasley, Nos. 95-3362, 95-3510 (8th Cir. Dec. 18, 1996))
  • Co-prosecutor in the conviction at trial on threat charges in a “stalking” and threatening letter campaign which escalated into the fire-bombing of two state court judges’ homes by the defendant; This case also resulting in a National Directors Award from the Bureau of Alcohol, Tobacco and Firearms (U.S. v Bellrichard, 994 F.2d 1318 (8th Cir. 1993))

Awards and Community

Recognized in The Legal 500 U.S. for Dispute Resolution: Corporate Investigations & White-Collar Criminal Defense, 2021

Recognized in the "GIR 100" by Global Investigations Review, 2020