Preston L. Pugh

Overview

Preston Pugh advises boards of directors and senior executives on complex issues at the intersection of governance, integrity, and enterprise risk. A former federal prosecutor, global compliance investigations leader, and twice-appointed compliance monitor, Preston brings over twenty-five years of experience helping public and private companies, universities, and multinational organizations navigate high-stakes investigations, board inquiries, related litigation, and reputational challenges. While most matters he works on are strictly confidential, matters in the public record include his current defense of a large integrated health care system in a publicized False Claims Act investigation and litigation involving the system’s 2017 and 2018 ACA rate submissions; his successful defense of a large convention and sports authority in a DOJ investigation focusing on allegations of conflicts and bid rigging by the authority’s CEO; and his leadership of an independent investigation into a university sports team in the wake of allegations of abuse, racism, and favoritism aired on CNN.

Preston is a longtime nonprofit board member and a member of both the National Association of Corporate Directors and Society for Corporate Governance. He conducts sensitive internal investigations, advises audit committees, provides updates to outside auditors, responds to U.S. congressional committees, and designs forward-looking compliance investigations programs that withstand regulatory scrutiny and outside stakeholder expectations. He helps leadership teams connect legal risk to business value — transforming enforcement lessons into frameworks for enterprise resilience.

Preston’s experience spans industries including health care, financial services, defense, insurance, technology, and higher education. He has led investigations and global risk assessments across Europe, the Middle East, and Asia-Pacific and represented clients in enforcement actions involving the False Claims Act, anti-corruption, whistleblower, corporate ethics, and ESG-related issues. He has also guided boards through allegations involving senior executives, workplace misconduct, and cultural risk—advising on strategy, communication, and stakeholder engagement.

Before private practice, Preston served as an Assistant U.S. Attorney in Chicago, handling complex investigations and trials. He later led global compliance investigations for a Fortune 10 business unit, giving him a rare dual perspective as both prosecutor and in-house compliance executive. Throughout his career, he has led more than 100 investigations, tried 15 cases as lead counsel, and argued cases in more than half of the U. S. Courts of Appeals.

Recognized among Savoy Magazine’s “Most Influential Lawyers” and The Legal 500’s top practitioners, Preston frequently speaks on DOJ policy, whistleblower developments, and the evolving expectations of boards and corporate monitors. He serves on the boards of the NYU Program on Corporate Compliance and Enforcement, the Federal Bar Association’s Qui Tam Section, and the National Legal Aid & Defender Association, and as liaison between the ABA Criminal Justice Section and the Department of Justice.

Preston is a longtime nonprofit board member and a member of both the National Association of Corporate Directors and Society for Corporate Governance. He conducts sensitive internal investigations, advises audit committees, provides updates to outside auditors, responds to U.S. congressional committees, and designs forward-looking compliance investigations programs that withstand regulatory scrutiny and outside stakeholder expectations. He helps leadership teams connect legal risk to business value — transforming enforcement lessons into frameworks for enterprise resilience.

Preston’s experience spans industries including health care, financial services, defense, insurance, technology, and higher education. He has led investigations and global risk assessments across Europe, the Middle East, and Asia-Pacific and represented clients in enforcement actions involving the False Claims Act, anti-corruption, whistleblower, corporate ethics, and ESG-related issues. He has also guided boards through allegations involving senior executives, workplace misconduct, and cultural risk—advising on strategy, communication, and stakeholder engagement.

Before private practice, Preston served as an Assistant U.S. Attorney in Chicago, handling complex investigations and trials. He later led global compliance investigations for a Fortune 10 business unit, giving him a rare dual perspective as both prosecutor and in-house compliance executive. Throughout his career, he has led more than 100 investigations, tried 15 cases as lead counsel, and argued cases in more than half of the U. S. Courts of Appeals.

Recognized among Savoy Magazine’s “Most Influential Lawyers” and The Legal 500’s top practitioners, Preston frequently speaks on DOJ policy, whistleblower developments, and the evolving expectations of boards and corporate monitors. He serves on the boards of the NYU Program on Corporate Compliance and Enforcement, the Federal Bar Association’s Qui Tam Section, and the National Legal Aid & Defender Association, and as liaison between the ABA Criminal Justice Section and the Department of Justice.

Career & Education

Department of Justice: United States Attorneys' Office
Northern District of Illinois: Assistant U.S. Attorney, 1999–2002
National Labor Relations Board
Appellate Court Branch, 1997–1999
- Department of Justice: United States Attorneys' Office
  Northern District of Illinois: Assistant U.S. Attorney, 1999–2002
- National Labor Relations Board
  Appellate Court Branch, 1997–1999
New York University School of Law, J.D., 1997
Cornell University, B.A., 1994
- New York University School of Law, J.D., 1997
- Cornell University, B.A., 1994
District of Columbia
Illinois
New York
Supreme Court of the United States
U.S. District Court for the Northern District of Illinois
U.S. Court of Appeals for the Sixth Circuit
U.S. Court of Appeals for the Seventh Circuit
- District of Columbia
- Illinois
- New York
- Supreme Court of the United States
- U.S. District Court for the Northern District of Illinois
- U.S. Court of Appeals for the Sixth Circuit
- U.S. Court of Appeals for the Seventh Circuit
Professional Activities and Memberships

Co-Chair, Global Anti-Corruption Committee, American Bar Association

Co-Chair, Qui Tam Subcommittee, Criminal Justice Section, American Bar Association

American Bar Association's Task Force on Corporate Monitors

Leadership Greater Chicago, Class of 2012

Former Member, Character and Fitness Committee, Illinois Attorney Registration and Disciplinary Committee

Former Chair, Labor and Employment Committee, Chicago Bar Association
Professional Activities and Memberships
- Co-Chair, Global Anti-Corruption Committee, American Bar Association
- Co-Chair, Qui Tam Subcommittee, Criminal Justice Section, American Bar Association
- American Bar Association's Task Force on Corporate Monitors
- Leadership Greater Chicago, Class of 2012
- Former Member, Character and Fitness Committee, Illinois Attorney Registration and Disciplinary Committee
- Former Chair, Labor and Employment Committee, Chicago Bar Association

Reflecting on Preston’s role in a landmark compliance monitorship, Preston was described as ‘that outsider coming in … not easy to do, but he did it well.’

— U.S. District Court in Chicago

Preston's Insights

Speaking Engagement | March 2025

"ABA National Institute on White Collar Crime," False Claims Act panel

Speaking Engagement | February 2025
Federal Bar Association Qui Tam Section Annual Program
Event
ABA White Collar Crime Conference 2024
Speaking Engagement | May 2024
"ABA International Law Section," Global Compliance Programs

View All Insights

Representative Matters

Board-Level Investigations

Led internal investigation into allegations by whistleblower in India, a former VP and head of global in-house operations for a NASDAQ-traded U.S. company, concerning bribery, kickbacks, discrimination, and other misconduct against the company’s CIO.
Led privileged internal investigation of whistleblower allegations regarding the CEO and general counsel of a Romanian subsidiary of Fortune 150 financial services company, focusing on allegations of bribery, ethical misconduct, harassment, and self-dealing that were made against the subsidiary’s GC and CEO.
Led privileged investigation into alleged misconduct by the chief actuary of a publicly traded financial services company.
Led privileged internal investigation of a whistleblower complaint regarding a Fortune 100 CEO and CHRO in the financial services industry for ethical misconduct. Included, at the company’s request, interviews of all members of the company’s executive management group and other corporate officers. Reported successful conclusion of the investigation to audit committee and general counsel.
Led investigation of whistleblower allegations for product safety noncompliance and failure to provide accurate testing reports to the company’s outside certifying body.
For a board of directors of a publicly traded company, led a comprehensive risk assessment of the company in Europe, the Middle East, Africa, U.S., and Asia Pacific covering anti-corruption, third-party due diligence, cartels, government contracts, trade controls, and the use, availability, and structure of its whistleblower reporting channels.
Investigated whistleblower allegations regarding accounting fraud by a U.S. subsidiary of a large publicly traded Japanese company, reporting results to external auditor. Investigation resulted in corrective action for subsidiary’s CFO and CEO.
Conducted a nine-month internal investigation of a health care medical device company regarding allegations of kickbacks, off-label marketing, and other health care compliance issues.
Led an independent investigation of alleged conduct by coaches on a Big Ten sports team, including highly publicized allegations by student-athletes of abuse, favoritism, and racism. Drafted public report issued to all university alumni.
Retained by a board of directors to investigate numerous code of conduct complaints against the CEO of a large hospital, including conflicts of interest and other allegations.
Led internal investigation of the chief of police of a large county authority. Allegations included workplace harassment, bullying, and discrimination spanning a decade. Reported to and advised executive director of the county, and also county board of director.

Government Investigations and Litigation

Defending Sentara Health in a DOJ False Claims Act investigation and subsequent qui tam litigation in connection with the provider’s submission of multiple years of state-approved ACA rate increases.
Defending a DoD government contractor in a DOJ False Claims Act investigation of several companies in cloud migration for alleged bid rigging, in violation of the False Claims Act.
Defended Big Ten university in congressional investigation by the House Select Committee on the CCP, resulting in favorable findings by the committee in a public report.
Successfully Defended DNC contractor in an investigation by the Senate Intelligence Committee into alleged improper activities that the contractor engaged in with Ukraine in the lead-up to the 2016 U.S. presidential election.
Led the successful defense of a large health care provider in a ten-month OSHA whistleblower investigation regarding allegations of noncompliance with OSHA safety reporting standards and the provision of N95 masks.
Successfully defended a large convention and sports authority in a grand jury investigation by the DOJ, focusing on allegations of conflicts and bid rigging by the authority’s CEO.
Successfully defended government contractor in arbitration filed by several employees who were terminated at the conclusion of a DOJ investigation for alleged falsification of timecards.
Successfully defended a large health care provider joint venture, facing claims by HHS-OIG of overbilling by more than $22 million. After considerable discussions with OIG, the government reversed its decision and decided against pressing any claims.
Represented one of the largest hospitals in the United States after the on-site homicide of a nurse-practitioner. Led a team to conduct an internal investigation of the homicide and hospital security protocols. Advised the hospital regarding communications and discussions with internal and external stakeholders. Represented the hospital in associated extensive OSHA investigation, which resulted in no adverse findings against the hospital.
Jointly led the internal investigation and defense of an airline in an industry-wide False Claims Act and false statements investigation by the DOJ and the U.S. Postal Service. The investigation was both domestic and global, took place over several years, and involved dozens of witnesses.
Defended FCA and criminal false statement allegations against a Division I university following a well-publicized 2013 dawn raid by 54 federal and state law enforcement agents. Advised university regarding crisis communications, discussions with law enforcement, internal and external stakeholders, and internal investigation of the issues. After several years, the DOJ closed the investigation with no charges filed.