Rohan Virginkar

Rohan Virginkar was a trial attorney in the Foreign Corrupt Practices unit of the Justice Department's criminal division fraud section.

He left the DOJ in the summer of 2017 to rejoin his old firm Foley & Lardner.

Virginkar worked on the FCPA settlement with Israeli business Teva Pharmaceuticals, which in December 2016 agreed to pay US$519 million to settle charges brought by the DOJ and the US Securities and Exchange Commission.

Virginkar was listed as the trial attorney in the declination letter sent by the DOJ in September 2016 to maintenance manufacturer NCH Corporation citing the FCPA pilot programme. The DOJ said employees at NCH’s Chinese subsidiary paid local government officials nearly US$45,000 to help secure sales. NCH agreed to disgorge US$335,342 in profits.

Trial attorney Rohan Virginkar joined the Justice Department in 2011 and set to work on the Deepwater Horizon Task Force prosecuting cases related to the Gulf of Mexico oil rig disaster in 2010.

He was cited in the Justice Department's November 2012 news release announcing that oil company BP Exploration and Production had reached a US$4 billion settlement to settle charges of felony manslaughter, environmental crimes and obstruction of Congress. At the time, the BP settlement was the single largest federal criminal penalty ever leveled. 

Virginkar came to the DOJ after seven years with Foley & Lardner, where he was an associate working on Foreign Corrupt Practices Act investigations. In a 2010 interview with the "FCPA Professor" blog author Mike Koehler, Virginkar described his first-ever FCPA assignment, given to him within months of starting at Foley & Lardner.

In Mumbai, he discovered that a manager of the Indian subsidiary of a US client had handed a duffel bag stuffed with cash to an official who had threatened to disrupt their business. The cash was supposedly a "donation" to the official's favourite charity.

"It was a valuable introduction to the FCPA: shakedowns by foreign government officials, 'charitable donations' to potentially suspect charities; it had many FCPA red flags all in one case," he said.

He also called the FCPA on balance a fair law, saying he wouldn't change it – except that he wished there were more clarifying case law on the 1977 statue.

Virginkar has another claim to fame: In 2001, shortly after graduating from college, he twice appeared on the television game show Jeopardy, winning a total of US$8,000.

Virginkar is a 2004 graduate of the George Washington University School of Law and a 2001 graduate of the University of California, Los Angeles, where he received a degree in political science. He hails from Diamond Bar, California.

He joined the fraud section's FCPA unit in mid-2014.

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