Mr. deGrasse is located in Chicago. He has led fraud investigations across a broad spectrum of industries in both a law firm and consulting context. He served as a law clerk to a federal judge in North Carolina for two years and then spent 10 years as a federal prosecutor in Raleigh and Chicago. He has been a partner at two international law firms and thereafter served as a partner at a Big Four accounting firm in its Forensics Practice for over 14 years. He served at the latter firm as Lead Partner for FCPA matters in the Americas. He has testified in a variety of settings, including before a US Senate subcommittee examining terrorist financing. He also has presented on FCPA matters at the annual DOJ/SEC “boot camp.”
- Mr. deGrasse has experience in various areas, including Foreign Corrupt Practices Act (FCPA), money laundering, health care fraud and abuse, corporate compliance programs (including executing internal audit programs), civil forfeiture, antitrust, labor racketeering and general commercial disputes. He has collaborated with senior management and boards of directors for companies of diverse size, from Fortune 5 companies to small privately held entities. He has lectured frequently on these topics to corporations and professional associations, the latter including the American Bar Association’s Litigation Section, the American Health Lawyers’ Association, the Health Care Compliance Association, the Illinois State Bar Association and the Institute of Internal Auditors, an organization that identified him as one of its outstanding presenters for 2010. He also has provided commentary and insight regarding criminal matters, including the FCPA on Chicago media outlets and in national publications.
- Mr. deGrasse has provided to the United States Senate, at the request of one of its committees, both information and background in order to assist that committee’s investigation into terrorist financing in the wake of the September 11th tragedy.
- Mr. deGrasse travels world-wide to address FCPA-related issues for clients, including in the due diligence, compliance, internal audit and investigative contexts. His work has included review of books and records, review and drafting of corporate policies and procedures, supervision of computer forensic projects, and interviews of corporate employees and other witnesses. He understands the inevitable investigative challenges that accompany cross-border FCPA investigations and due diligence engagements. He worked closely with firm global resources to understand pertinent cultural, statutory and regulatory frameworks relevant to investigations in foreign countries. He conducts and supervises internal forensic investigations for a broad spectrum of businesses, often addressing issues with audit committees and members of senior management.
- Mr. deGrasse also advises companies on establishing and implementing corporate compliance and governance programs. His work includes review of controls addressing both regulatory and financial risk as well as designing and executing internal audit work plans. He works frequently with general counsel, chief compliance officers and heads of internal audit in this regard.
- Mr. deGrasse earlier served as an Assistant U.S. Attorney for the Northern District of Illinois and Eastern District of North Carolina, where he tried more than 25 cases in federal court and argued numerous cases on appeal before federal appellate courts. His prosecutions included corrupt union officials, organized crime figures, and members of the Cali Cartel’s international money laundering network. His work included participating in civil forfeitures related to organized crime and drug trafficking prosecutions, including the tracing of assets linked to illegal activity. Prior to practicing law in Chicago he served as law clerk to U.S. District Judge Terrence W. Boyle in Elizabeth City, NC and later as an Assistant U.S. Attorney in the Eastern District of North Carolina, where he focused on drug importation, money laundering and financial fraud cases.
- Mr. deGrasse was one of five prosecutors selected nationwide by the U.S. Department of Justice to restructure the Department’s most advanced educational course for federal prosecutors. He also frequently lectured at that course and others sponsored by the Department.
Select Compliance and Investigative Experience
- Walmart Stores, Inc. retained deGrasse to assist with its FCPA compliance efforts on a global basis. Mr. deGrasse served as his firm’s global lead partner for this large and complex project, which had within its scope operations in numerous foreign jurisdictions.
- Assisted nearly two dozen clients in performing Foreign Corrupt Practices Act due diligence in regard to various potential international acquisition targets, including native language capabilities, a review of pertinent compliance programs, testing of samples based on a risk-based judgmental sampling methodology, review of internal controls processes, and on-site interviews. These projects have occurred in both the auction and exclusive bidding context. The deal size has ranged from slightly over $1 million to over $1 billion. The industries range from biochemical companies to an international race car circuit.
- Assisted several corporate entities with creating and executing internal audit work plans focusing in FCPA-related risk, including analysis and interviews in numerous foreign jurisdictions
- Assisted a client in the manufacturing sector with investigating potential violations of the FCPA and U.S. export controls laws in relation to the client’s dealings with Iran, Syria, Sudan and Cuba, which included an analysis of domestic and foreign financial records and the conducting of interviews in Belgium, Spain, Germany and Turkey.
- Managed an investigation into alleged FCPA violations involving a Fortune 200 corporation’s Asian subsidiary. The investigation included using various forensic investigative tools and techniques on a global basis, including native language capabilities, interviews, forensic accounting and computer forensic capabilities.
- Managed an investigation into alleged FCPA violations involving the Mexican subsidiary of a SEC registrant in the energy industry. The investigation included using various forensic investigative tools and techniques, including native language capabilities, interviews, forensic accounting and computer forensic capabilities.
- Assisted a Fortune 100 company in an internal assessment of its global compliance plan in regard to general investigative and FCPA-specific protocols, including travel with its general counsel and head of internal audit to multiple locations in the Peoples Republic of China and a redrafting of all its policies in this regard.
- Assisted a large US-based bank with international obligations with a review and assessment of its global money laundering program in response to a government investigation. Assisted in the revising of various components of the program.
- Assisted a multi-national pharmaceutical company in an international investigation involving possible bribe payments to customs officials in South America.
- Assists various Fortune 200 clients in performing Foreign Corrupt Practices Act due diligence in regard to various potential international acquisition targets, including undertaking background checks, a review of pertinent financial records and on site interviews.
- Managed an investigation into a financial statement reporting fraud for a Fortune 200 corporation. The investigation involved international affiliates and the recording of revenue levels in the consolidated financial reporting process. His investigative team assisted outside counsel in successfully resolving the matter.
- Managed an investigation that included tracing of assets generated through illegal activity associated with Martin Frankel. The investigation was undertaken in connection with litigation involving insurance coverage issues. His firm was tasked with identifying the origins of specific funds under Frankel’s control and his subsequent transfers of those funds between various financial institutions.
- Served on an engagement in which his firm was the Independent Review Organization pursuant to a Corporate Integrity Agreement between the Department of Health & Human Services’ Office of Inspector General (“OIG”) and a global provider of health care services. Served as team liaison with the OIG.
- Managed an investigation on behalf of a multinational business into questionable vendor invoices. The investigation revealed that several suppliers that charged inflated rates were related parties. The client used his investigative findings to obtain a favorable settlement.
- Assisted a financial institution in analyzing questionable international and domestic monetary transactions with national security ramifications. Participated in recommending improvements in the client’s Anti-Money Laundering and compliance functions.
- Managed an investigation of possible embezzlement by a bank loan officer over the course of several years. Assisted outside counsel in providing investigative services to the victimized financial institution. The matter was referred to federal prosecutorial authorities, and an indictment was filed against the employee charging those transactions which deGrasse’s forensic team identified.
- Assisted a Fortune 200 company in an international investigation involving potential violations of the FCPA, OFAC and miscellaneous export regulations. Assisted client in collecting pertinent records, including coordinating clandestine office searches on a global basis; coordinated; participated in witness interviews on global basis.
- Assisted a large international client in investigating suspected kickbacks and accounting fraud in its corporate office, including the use of forensic data mining tools. Assisted that same client in investigating a suspected embezzlement scheme in one of its operating divisions.
- Managed an investigation into alleged FCPA violations involving an Argentinian subsidiary of a Fortune 500 packaging company. The investigation revealed the use of customs agents to facilitate bribes to customs officials in order to import prohibited equipment and to avoid high government duties imposed on certain scrap metal exports.
Juris Doctorate, Valparaiso University School of Law, 1984
Bachelor of the Arts, University of Notre Dame, 1981
Practices +Insights +
Chicago Public Library Foundation Board of Directors
Chicago Crime Commission. Board Member and Secretary, 2007-2009. Board Member, 2006 to present.
Illinois State Bar Association. Former Investigator, Judicial Evaluation Committee; Former Member, Civil Practice and Procedure Section Council; Former Member, Legal Education and Competency Committee.
American Bar Association. Member of International, Criminal Justice, Business, and Litigation Sections. Past Co-Chair, Public Corruption and FCPA Committee.
Valparaiso School of Law Alumni Board of Directors. Vice-President, 2005-2007 term; Secretary, 2004-2005 term.
Member, International Bar Association