William P. Barry
Member
Chair, Litigation Department
William Barry is the Chair of Miller & Chevalier's 40-person Litigation department. He is a trusted advisor to multinational companies, boards of directors, foreign trustees, hedge funds, private equity funds, universities, and senior officers and executives. For 30 years he has solved complex problems involving multi-jurisdictional investigations and litigation, as well as enforcement, compliance, and transactional issues. He helps his clients emerge from crises and resume focus on their business.
Client feedback in Chambers USA describes Will as "the kind of person that everyone in the boardroom listens to" and notes he is "tenacious, creative and goes the extra mile" and describes Will as "a problem solver, anticipating his client's needs at every turn and seeking a resolution that works for their business." When it comes to interaction with government regulators, feedback in Chambers USA describes Will as "a very thorough thinker, very calm, and is the ideal ambassador for corporations when dealing with government agencies" and states that Will "has not only the gravitas with the regulators, but he can pick up the phone and get their attention on a matter, which is a real benefit."
Will guides clients through the complex issues involved in responding to inquiries from domestic and international regulators regarding accounting fraud, terrorist- financing, foreign bribery, money laundering, economic sanctions, and other financial crimes. He represents clients faced with the challenge of responding to competing demands in parallel proceedings, such as internal reviews, government investigations, and private civil actions. He oversees multi-jurisdictional litigation matters, providing strategic oversight, directing local counsel, and ensuring a coordinated approach. He is an expert in governance matters, particularly with respect to boards of directors, and often conducts sensitive investigations and analyses for boards and board committees.
Will has been recognized repeatedly by Chambers Global, Chambers USA, Benchmark Litigation, Legal 500, Who's Who Legal, and other respected legal publications for his expertise in white collar defense, Foreign Corrupt Practices Act (FCPA) investigation and defense, securities enforcement, and litigation. He has obtained numerous declinations and favorable resolutions for clients involving allegations of non-U.S. and U.S. corruption, financial fraud, money-laundering and economic sanctions violations, insider trading, and securities and tax fraud.
Will is a member of the American Bar Association's (ABA) International Anti-Money Laundering (AML) Committee and International Anti-Corruption Committee. He has been designated as a Certified Anti-Money Laundering Specialist by the Association of Certified Anti-Money Laundering Specialists (ACAMS).
Will is a member of the board of the Washington Lawyers Committee for Civil Rights and Urban Affairs and the former Chairman of Olney Boys & Girls Club, a non-profit sports association in Maryland.
Representative Engagements
Crisis Management
- Represented a multinational telecom in connection with information leak leading to allegations of terrorist financing and related misconduct
- Coordinated crisis management response for a sovereign following allegations of unlawful surveillance, kidnapping, and torture
- Represented an Asian energy industry company in connection with investigation and related media attacks based on allegations of criminal circumvention of U.S. customs requirements
- Directed the crisis management response for a multinational religious organization in connection with criminal, civil, and fraud investigations following the assassination of a government official in Japan
- Directed the crisis management response for the senior staff of former prime minister of Middle Eastern government following a regime- change and related allegations of fraud and self-dealing
Anti-Corruption
- Represented a global communications company in connection with a federal investigation into terrorist- financing through corrupt payments
- Represented Albemarle in the global resolution of FCPA investigations by the U.S. Department of Justice (DOJ), U.S. Securities and Exchange Commission (SEC), and Dutch authorities
- Represented Ericsson in the resolution with DOJ regarding non-criminal breaches of its 2019 Deferred Prosecution Agreement (DPA)
- Secured a declination from the DOJ and SEC in a corruption investigation of a Latin American oil and gas company
- Secured a declination from the DOJ and SEC in a corruption investigation of a multi-national food processing company
- Secured a declination from the DOJ in a corruption investigation of a global manufacturer in the paper industry
- Secured declinations from the DOJ and SEC on behalf of a U.S. telecommunications company in connection with parallel criminal and civil investigations into allegations of FCPA violations
- Represented the audit committee of a global asset manager in conducting an independent investigation and interacting with U.S. regulators regarding allegations of FCPA violations, economic sanctions, and money laundering in connection with investments in North Africa and Sub-Saharan Africa
- Represented the board of directors of a petroleum industry Fortune 100 multinational corporation headquartered in Latin America relating to U.S. regulatory matters, including government investigation and civil litigation
Securities Enforcement and Financial Services
- Conducted an audit committee investigation into reserve accounting issues at a U.S.-listed, multi-national retailer in connection with SEC investigation
- Conducted audit committee investigation for a U.S.- and Canadian-listed public company regarding an independent investigation into revenue recognition and reserve accounting issues in connection with SEC investigation
- Secured declination for U.S.-listed Swiss manufacturing company in connection with SEC investigation into reserve accounting issues
- Secured declination for an investment adviser in connection with SEC insider trading investigation involving a global pharmaceutical company
- Defended Fortune 2000 telecom company in SEC investigation involving books and records and internal controls allegations
- Advised board of Fortune 500 company in connection with an SEC investigation involving accounting, earnings and disclosure matters
- Advised an engineering and manufacturing company in connection with allegations of material weaknesses in the company’s internal controls for financial reporting and related interactions with the company’s audit firm
AML, Economic Sanctions, and the Uyghur Forced Labor Prevention Act (UFLPA)
- Represented employees of non-U.S. bank in connection with an investigation by the Southern District of New York (SDNY) and the New York County District Attorney's Office (DANY) into potential violations of U.S. economic sanctions implemented under the Trading with the Enemy Act of 1917 (TWEA) and the International Emergency Economic Powers Act (IEEPA) and administered by the Department of the Treasury's Office of Foreign Assets Control (OFAC)
- Advised commodities trader in connection with DOJ investigation into allegations of violations of economic sanctions
- Conducted independent BSA audit for registered investment adviser
- Conducted AML compliance reviews hedge funds and private equity funds
- Represented renewable energy company in connection with Department of Homeland Security (DHS) and DOJ investigation into allegations of violations of forced labor and related customs
Individual Representations
- CEO of an AI technology company in connection with allegations of accounting fraud and other violations of the federal securities laws
- CEO of a Fortune 25 technology company in SEC accounting investigation
- CFO of a Fortune 500 telecom company in SEC accounting investigation
- Head of Internal Audit of a multi-national construction company in a DOJ and SEC investigation into FCPA allegations
- C-Suite of a medical device company in a DOJ and SEC investigation into securities fraud allegations
- CFO of a multinational health care company in connection with allegations of fraud and violations of the FCPA
Civil Litigation and Fraud
- Represented a multinational investment group in connection with claims of unlawful conversion regarding oil and gas concession
- Represented a film production company in connection with fraud claims against foreign sovereign and related allegations of corruption
- Represented the defendant in offshore litigation in procuring relief through access to foreign discovery pursuant to 28 USC 1782
- Developed and oversaw the litigation strategy in a multi-billion-dollar embezzlement matter including asset tracing, Mareva, and other injunctive relief and coordination of counsel in multiple countries and jurisdictions
- Defended the officer of a multinational insurance company in connection with derivative action
Trustee and Family Office Representations
- Defended a foreign trustee company with respect to a criminal tax investigation of "largest ever tax charge against an individual" involving the DOJ and regulators in multiple offshore jurisdictions
- Represented a foreign trustee with respect to U.S. economic sanctions, tax, and trust governance issues in connection with OFAC inquiry
- Secured a declination for foreign trustees in connection with parallel enforcement, tax, and money laundering investigations by the SDNY U.S. Attorney's Office, SEC, and Permanent Subcommittee on Investigations of the U.S. Senate
- Defended a foreign trustee in connection with DOJ investigation into Pandora Papers investigation involving corruption, economic sanctions, and money-laundering allegations
Rankings and Recognition
- Chambers USA: FCPA (Nationwide), 2021 - 2024
- Chambers USA: Litigation: White-Collar Crime & Government Investigations (District of Columbia), 2022 - 2024
- Chambers Global: FCPA (United States), 2022 - 2025
- The Best Lawyers in America®: Criminal Defense: White Collar, 2021 - 2025
- Legal 500: Dispute Resolution: Corporate Investigations and White-Collar Criminal Defense, 2013 - 2016, 2018 - 2023
- Legal 500 Latin America: International Firms: Compliance and Investigations, 2022 - 2025
- Who's Who Legal: Investigations, 2022 - 2024
- Benchmark Litigation: National Star for White Collar Crime and Securities Litigation, 2017 - 2018, 2022 - 2023
Affiliations
- Member, ABA Anti-Money Laundering Committee
- Member, ABA International Anti-Corruption Committee
- Certified Anti-Money Laundering Specialist, ACAMS
- Board Member, Washington Lawyers Committee for Civil Rights and Urban Affairs
- Former Chairman, Olney Boys & Girls Club
Admissions
State Admissions
- District of Columbia
- Massachusetts
Court Admissions
- United States District Court for the District of Columbia
- United States District Court for the District of Massachusetts
- District of Columbia Court of Appeals
Clerkships
- Clerk, The Honorable Truman A. Morrison III, District of Columbia Superior Court, 1995 – 1996
News and Events
Events
Speaking Engagement
ACI International Conference on the FCPA
Speaking Engagement
Representing Organizations in Multinational Investigations: A Comparative U.S.-EU Discussion
Speaking Engagement
Private Wealth U.S. Retreat
Speaking Engagement
Economic Crime Prevention Switzerland
Speaking Engagement
Defendtech Symposium: Elevating Defense through ITAR and Sanctions Mastery
Publications
Internal Publication
Proceed with Caution: While FCPA Enforcement is Paused, Fraud and Bribery Risks Remain
Internal Publication
Actions by the Trump Administration Increase the Risk for Corporations Interacting with Cartels
Internal Publication
Money Laundering Enforcement Trends: Winter 2024
Internal Publication
Money Laundering Enforcement Trends: Spring 2024
External Publication