Bret A. Campbell

Washington,  DC  U.S.A.
Phone202 862 2253

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Practice Areas

  • Anti-Money Laundering & Asset Forfeiture
  • Business Fraud & White Collar Defense
  • Commercial Bribery & FCPA
  • Corporate & Securities Litigation
  • Corporate Governance
  • Cyber and National Security
  • FCPA and International Anti-Bribery
  • False Claims Act
  • Financial Regulation
  • Government & Internal Investigations and Defense
  • Litigation
  • OFAC and Export Control
  • Pharmaceutical Regulation and Compliance
  • Securities Enforcement & Investigations
Contact InfoTelephone: 202 862 2253
Fax: 202 862 2400
University Hobart and William Smith Colleges, B.A., with honors, 1989
Law SchoolVermont Law School, J.D., cum laude, 1994
Admitted1995, Massachusetts; 1996, New York and District of Columbia; U.S. District Court, District of Columbia

Bret Campbell is a partner in the White Collar Defense and Investigations Group in the Washington, D.C. office. Bret represents clients in a broad range of complex criminal, regulatory, and civil litigation matters involving international corruption and the Foreign Corrupt Practices Act, as well as securities, healthcare, accounting, and commercial fraud. He has extensive experience managing internal corporate investigations and cross-border criminal and regulatory matters, often in proceedings before the U.S. Department of Justice and the Securities and Exchange Commission. Other civil litigation experience includes representing clients in federal trial and appellate courts in matters involving contractual disputes, fraud, insurance coverage, employment issues, intellectual property rights and antitrust claims.

In addition to his litigation practice, Bret conducts FCPA and regulatory compliance due diligence reviews in connection with mergers, acquisitions, and other complex corporate transactions. He has directed numerous global due diligence reviews of proposed investments and business combinations in industries and jurisdictions presenting significant risks of corruption and fraud.

Bret also advises clients on corporate governance issues and on the implementation of compliance codes. He helps companies assess risks in their international operations, and counsels on the development and implementation of policies, procedures, and systems designed to prevent and detect potential violations of law. Bret regularly provides training on FCPA and related issues to his clients' legal, compliance and internal audit departments.

His clients include U.S. and foreign companies and individuals in the pharmaceutical, energy, medical device, telecommunications, financial services, defense, computer software, and aerospace industries. Recent engagements include litigation and internal investigations involving activities in Western and Eastern Europe (including Russia), Asia, Africa, the Middle East, Latin America and South America.

Bret writes and speaks frequently on regulatory, criminal law, and compliance issues, and has served as a faculty member of Seton Hall Law School's Healthcare Compliance Certification Program. He has spoken at events for the American Conference Institute, the Pharmaceutical Compliance Congress and Best Practices Forum, the Practising Law Institute, the Society of Corporate Compliance and Ethics, the Pharmaceutical Internal Audit Forum, and has co-chaired the American Conference Institute's annual conference on FCPA & Anti-Corruption for the Life Sciences Industry.

He received a B.A., with honors, in 1989 from Hobart College, and a J.D., cum laude, in 1994 from Vermont Law School. Bret is admitted to practice in the District of Columbia, the State of New York, and the U.S. District Court for the District of Columbia.

News Releases

• Cadwalader Garners Multiple Burton Legal Writing Honors Jun 12, 2012

• Cadwalader Promotes Four to Partnership Jan 05, 2010

Recent Press

• Cadwalader Partner Bret Campbell on Being Caught Between a Great Wall and a Hard Place Mar 03, 2014

• Hedge Funds with SWF Clients Should Re-Jig Compliance Operations Mar 28, 2011


• 2012 Burton Awards for Legal Achievement Jun 12, 2012

Clients & Friends Memos

• First Amendment and Off-Label Promotion - Prosecute What I Do, Not What I Say Apr 21, 2014

• Ninth Circuit's Harkonen Decision Does Not Undermine Recent Second Circuit Precedent Establishing That Truthful Promotion Of Approved Drugs For Off-Label Use Is Protected By The First Amendment Mar 22, 2013

• Federal Court Finds that FDA Drug Approval is not Complete Defense to False Claims Act Allegation Involving On-Label Promotion Feb 21, 2013

• Second Circuit's Caronia Decision Striking Down On First Amendment Grounds The Criminal Conviction Of A Pharmaceutical Sales Representative For Off-Label Promotion Could Have Broad Implications Jan 04, 2013

• First Circuit Set to Weigh in on Significant Circuit Split Involving False Claims Act First to File Rule Nov 23, 2012

• U.S. Court of Appeals for D.C. Circuit Affirms Exclusion From Federal Health Care Programs Under “Responsible Corporate Officer” Doctrine Aug 06, 2012

• The Bribery Act 2010: Are You Ready? Jun 30, 2011

• SEC Launches FCPA Probe of Financial Services Industry's Interactions with Sovereign Wealth Funds Mar 18, 2011


• UK Issues Sentencing Guideline for Individuals Convicted of White-Collar Offenses Aug 01, 2014

• Caught Between a Great Wall and a Hard Place: Issues For U.S. Public Companies in Responding to Regulatory Requests for Chinese Data Mar 31, 2014

• U.K. Guidelines Emphasize Importance of Robust Programs Mar 17, 2014

• 1st Circ. Set To Weigh In On FCA First-To-File Rule Dec 04, 2012

• Circuit Affirms Exclusion from Federal Health Care Programs under Responsible Corporate Officer Doctrine: Companies and Executives Beware of an Emboldened Department of Justice and HHS Office of Inspector General Oct 01, 2012

• SEC Launches FCPA Probe of Financial Services Industry's Interactions With Sovereign Wealth Funds Aug 01, 2011


• FCPA in 2014 & Beyond Sep 10, 2014

• Seton Hall Law School West Coast Biotech Compliance Conference Sep 08, 2014

• 9th Annual Homeland Security Law Institute Aug 21, 2014

• ACI's 8th Advanced Forum on FCPA & Anti-Corruption for the Life Sciences Industry Apr 28, 2014

• The American Bar Association's 28th Annual National Institute on White Collar Crime Mar 05, 2014

• Seton Hall Law School Healthcare Compliance: FCPA Oct 14, 2013

• Events In The Nation's Capital Continue To Impact Enforcement And Compliance Efforts Jul 09, 2013

• Forum on Anti-Corruption Jun 25, 2013

• The Global Anti-Corruption Congress Jun 18, 2013

• Healthcare Compliance Program: FCPA Jun 10, 2013

• FCPA and Anti-Corruption for the Life Sciences Industry May 14, 2013

• Corporate Compliance & Regulatory Update Conference 2013 Apr 29, 2013

• FCPA and the Life Sciences Industry Oct 10, 2012


FCPA Advisor

• Canadian Court Hands Down First Prison Sentence Under Corruption of Foreign Public Officials Act Jun 03, 2014

• Will Independent Directors Be on the Hook for Failure of Internal Controls in FCPA Cases? Jul 15, 2013

• Allianz To Pay $12.3M To Settle SEC's Bribery Allegations Dec 19, 2012

• DOJ and SEC Issue FCPA Guidance Nov 19, 2012

• FCPA Allegations Involving Customs Clearance in Kazakhstan Jun 11, 2012

• Lindsey Manufacturing's Conviction Overturned Dec 05, 2011

• With Publication of Final Guidance, UK Bribery Act to Go Into Effect on July 1, 2011 Apr 15, 2011

• U.K. Ministry of Justice Further Delays Implementation of Bribery Act Feb 03, 2011

• New Compliance Criteria Set in Sentencing Guidelines Nov 30, 2010

• ABB Entities Resolve FCPA Investigation Nov 30, 2010

• Panalpina, Shell, Four Oil Services Companies Settle FCPA Charges Nov 30, 2010

• Intermediaries Indicted for Involvement in Scheme to Bribe Mexican Officials Sep 29, 2010

• U.K. Ministry of Justice Releases Guidance on Bribery Act Sep 29, 2010

• Department of Justice Issues FCPA Opinion Procedure Release on the Definition of the term “Foreign Official” Sep 03, 2010

• Alliance One and Universal Corp Settle DOJ, SEC Charges; Former Country Manager of Alliance One Pleads Guilty Aug 16, 2010

• Giffen Pleads Guilty to Misdemeanor Tax Violation 7 Years After FCPA-Indictment; His Merchant Bank Pleads Guilty to FCPA Felony Aug 16, 2010

• Department of Justice Issues Second FCPA Opinion Procedure Release for 2010 Regarding Government Compelled Grants and Due Diligence Aug 02, 2010

• GE Agrees to Pay $23.4 Million to SEC to Settle FCPA Charges Jul 29, 2010

• Implementation of U.K. Bribery Act Delayed Until April 2011 Jul 26, 2010

• ENI and Snamprogetti Settle Criminal and Civil Charges Related to the Bonny Island Project in Nigeria; JGC Corporation Discloses Settlement Discussions Jul 15, 2010

• Breuer Cautiously Approaches Costly FCPA Cases Jul 02, 2010

• Financial Reform Bill Compensates Whistleblowers Assisting the SEC Jul 02, 2010

• Technip Enters into DPA with DOJ, Pays $338 Million Settlement Jul 02, 2010

• Department of Justice Guidance on Company Disputes with Corporate Monitors Jul 02, 2010

• First DOJ FCPA Opinion Procedure Release in 2010 Jul 02, 2010

SEC Enforcement Advisor

• SEC Announces Largest Ever Whistleblower Award, Awards $30 Million to Foreign Whistleblower Oct 01, 2014

• Second Circuit Holds that Anti-Retaliation Provisions of Dodd Frank Act Have No Extraterritorial Application Aug 20, 2014

• Gatekeepers In the Enforcement Spotlight May 22, 2014

• SEC Announces Second Set of Whistleblower Awards Jul 01, 2013

• The SEC's New Policy on Seeking Admissions in Settlements Jun 28, 2013

White Collar Defense and Investigations Advisor

• AML Guidance Issued for Banks Seeking to Service Marijuana-Related Businesses Feb 27, 2014

• SEC Issues Guidance on Conflict Minerals Rule Jun 10, 2013

• U.S. and Chinese Regulators Sign Historic Memorandum of Understanding Regarding Enforcement Cooperation May 31, 2013

• Southern District of New York Orders Chevron CEO and General Counsel to Testify in RICO Suit Related to $18 Billion Ecuadorian Judgment May 28, 2013

• European Union Pending Legislation Requiring Additional Transparency from Extractive Industries May 20, 2013

• A Brief Primer for Corporate Social Media Disclosures in Light of the SEC's Recent Guidance on Regulation FD Apr 08, 2013

• The Dodd-Frank Whistleblower Program: An Analysis of the SEC's Second Annual Report, Best Practices for Dealing with Whistleblowers, and Recent Cases Interpreting the Scope of the Anti-Retaliation Provisions of the Dodd-Frank Act Dec 10, 2012

• SEC Issues Resource Extraction Rule Sep 21, 2012

• SEC Issues Conflict Minerals Rule Aug 29, 2012

• The Evolving Obligations of Public Companies to Disclose Cyber-Intrusions Jul 09, 2012

• Justice Department Establishes Residential Mortgage-Backed Securities Working Group Jan 31, 2012

• The Dodd-Frank Whistleblower Provisions: Considerations for Effectively Preparing for and Responding to Whistleblowers May 26, 2011

• FinCEN Issues Final Rule on Foreign Bank Account Reporting (FBAR) Mar 01, 2011

• European Court of Justice Declares Corporate Communications With In-House Counsel Not Protected by Legal Professional Privilege Sep 17, 2010

• Barclays Bank PLC Forfeits $298 Million for Violations of U.S. Economic Sanctions; U.S. Judge Questions Use of DPA, Lack of Individuals Prosecuted Aug 19, 2010

• The Comprehensive Iran Sanctions, Accountability and Divestment Act of 2010 Jul 26, 2010

• New Whistleblower Compensation Enacted for Securities and FCPA Disclosures Jul 26, 2010

• SEC and Goldman Sachs Agree to Settle Historic Market-Crisis Enforcement Action Jul 19, 2010

• Supreme Court Limits Application of the Honest Services Fraud Statute Jul 15, 2010


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First Amendment and Off-Label Promotion - Prosecute What I Do, Not What I Say
Bret A. Campbell,Jason Jurgens,Adam S. Lurie,Brian T. McGovern,Martin L. Seidel, April 23, 2014
On December 3, 2012, the United States Court of Appeals for the Second Circuit vacated the conviction of Alfred Caronia (“Caronia”), who had been tried and convicted of participating in an unlawful conspiracy to introduce a misbranded drug into interstate commerce in violation of the...

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Office Information

Bret A. Campbell

700 Sixth Street, N.W.
WashingtonDC 20001


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