Thomas A. Hanusik

Partner

Overview

Whether defending government inquiries or conducting internal investigations, companies and individuals need legal counsel with prosecutorial and white collar defense experience, credibility, and first-hand knowledge of the priorities of regulators and law enforcement officials. As a former federal prosecutor who served on DOJ’s Enron Task Force and led numerous other high-profile investigations, Tom is valued by his clients not only as a strategic and effective counsel, but also as a trusted advisor.

Tom defends publicly traded and privately held companies, senior executives, board members and politicians across the spectrum of internal and government investigations, criminal and civil trials, regulatory enforcement actions, and appeals. With a focus on white collar defense, SEC enforcement, FINRA enforcement and internal investigations, Tom draws on over 30 years of experience to conduct internal investigations, negotiate favorable resolutions, lead trial and appellate teams, and advise on remedial measures, compliance programs and training.

Tom's recent engagements include representing institutions and executives in matters involving alleged violations of federal securities laws such as financial fraud, insider trading, FCPA and Reg S-K, AML prohibitions, federal and state tax statutes, public corruption laws, and U.S. export controls and sanctions regulations.

Before joining Crowell & Moring, Tom spent almost 12 years at the U.S. Department of Justice and the Securities and Exchange Commission. While at DOJ, Tom was one of the original prosecutors on the Enron Task Force, where he successfully prosecuted a number of senior executives and external advisers. He was then promoted to assistant chief in the Criminal Division, Fraud Section, where he led securities fraud investigations and prosecutions. Prior to joining DOJ, Tom was senior counsel in the SEC's Division of Enforcement, where he successfully prosecuted a series of insider trading and financial fraud cases.

Throughout his service at DOJ and SEC, Tom led, supervised, and coordinated a number of parallel criminal grand jury and civil law enforcement investigations. He also led the negotiation of numerous corporate-level dispositions on behalf of the government, including civil injunctive actions, cease-and-desist proceedings and criminal deferred-prosecution and non-prosecution agreements.

Since 2014, Tom has been nationally ranked in Chambers USA for White-Collar Crime and Government Investigations; he has likewise been ranked, since 2021, for FCPA. He is a member of the firm’s White Collar & Regulatory Enforcement Group, which Law360 previously named a "White Collar Group of the Year" and one of ten "FCPA Powerhouses.” He also chairs the Investigations Practice, is a member of the White Collar Group’s Steering Committee, and a former member of the firm’s Management Board.

Career & Education

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    • Department of Justice: Criminal Division
      Assistant Chief, 20042006
      Senior Counsel for Securities Fraud, 20032004
      Trial Attorney, 19982003
    • Department of Justice: Enron Task Force
      Prosecutor, Enron Task Force, 20022003
    • Securities and Exchange Commission
      Senior Counsel, Division of Enforcement, 19941998
    • Department of Justice: Criminal Division
      Assistant Chief, 20042006
      Senior Counsel for Securities Fraud, 20032004
      Trial Attorney, 19982003
    • Department of Justice: Enron Task Force
      Prosecutor, Enron Task Force, 20022003
    • Securities and Exchange Commission
      Senior Counsel, Division of Enforcement, 19941998
    • Fordham University, A.B., 1986
    • Duke University School of Law, J.D., 1990
    • Fordham University, A.B., 1986
    • Duke University School of Law, J.D., 1990
    • District of Columbia
    • New York
    • District of Columbia
    • New York
    • American Bar Association
    • Association of Securities and Exchange Commission Alumni, Inc.
    • EBW Inn of Court
    • American Bar Association
    • Association of Securities and Exchange Commission Alumni, Inc.
    • EBW Inn of Court

Tom’s Insights

Firm News | 8 min read | 08.15.24

The Best Lawyers in America 2025 Recognizes 42 Crowell & Moring Attorneys, Three Selected as Lawyer of the Year

Washington – August 15, 2024: The 2025 edition of The Best Lawyers in America® has recognized 42 Crowell & Moring lawyers as "Best Lawyers" and 29 lawyers as “Ones to Watch.”...

Representative Matters

  • Conducted an internal investigation in Argentina and led the self-reporting to and negotiations with the SEC and DOJ on behalf of client Ralph Lauren Corporation in a matter involving allegations of Foreign Corrupt Practices Act (FCPA) violations. Result: successfully resolved the case through unprecedented dual non-prosecution agreements (NPA) with the SEC and DOJ, including the first NPA provided by the SEC to an issuer in an FCPA matter. [Click here for related coverage]
  • Defended a CFO of a publicly traded company in an SEC investigation and litigation where the charges included multiple violations of the antifraud provisions of the federal securities laws. Result: secured an unprecedented summary judgment ruling denying the SEC's efforts to obtain any injunctive relief or officer and director bar. [Click here for the court opinion]
  • Defended a registered investment advisor group following an SEC-OCIE examination and issuance of a lengthy deficiency letter. Result: convinced the SEC to close the matter without any enforcement action against the group or its executives.
  • Represented a well-known broker-dealer as lead counsel in FINRA enforcement investigation regarding allegations of trading unregistered securities without appropriate money-laundering detection capabilities in place. Negotiated a favorable settlement with FINRA.
  • Defended a CEO and his businesses during a federal criminal tax investigation. Result: after numerous productions and presentations, IRS-CID closed its investigation without taking any action.
  • Defended publicly traded and privately held companies and executives, including CEOs, in the midst of several Securities and Exchange Commission (SEC) and U.S. Department of Justice (DOJ) investigations involving alleged FCPA violations. Results: secured declinations, public and private non-prosecution agreements and deferred-prosecution agreements for these clients.
  • Conducting internal investigations domestically and abroad for clients confronting FCPA issues and leading the self-reporting efforts to DOJ and SEC.
  • Defending senior executives at publicly traded financial institutions and mortgage securitization companies in connection with SEC and DOJ investigations regarding the subprime crisis.
  • Defending publicly traded companies, board members and outside counsel responding to Financial Industry Regulatory Authority (FINRA) and SEC inquiries concerning potential insider trading.
  • Defending numerous senior executives of publicly-traded companies in SEC accounting fraud-revenue recognition investigations.
  • Defending a Registered Representative in connection with a market manipulation investigation by the SEC.
  • Defending elected federal officials, law firms and lawyers involved in grand jury investigations involving allegations of public corruption.

Tom’s Insights

Firm News | 8 min read | 08.15.24

The Best Lawyers in America 2025 Recognizes 42 Crowell & Moring Attorneys, Three Selected as Lawyer of the Year

Washington – August 15, 2024: The 2025 edition of The Best Lawyers in America® has recognized 42 Crowell & Moring lawyers as "Best Lawyers" and 29 lawyers as “Ones to Watch.”...

Recognition

  • Chambers USA: White–Collar Crime & Government Investigations, Nationwide, 2014–2024
  • Chambers USA: FCPA, Nationwide, 2021–2024
  • Edward Bennett Williams Inn of Court: Barrister
  • Duke Law Alumni Association: Board of Directors
  • Assistant Attorney General: Award for Financial Integrity 
  • Attorney General and the FBI Director: Letters of commendation 
  • Special Achievement Awards and Meritorious Awards for exemplary service
  • United States Attorney for the Eastern District of Virginia: Award for Public Service  
  • Strategic Business Acceptance Subcommittee: Chair
  • ABA National Institute on Securities Fraud: Co–chair
  • ABA Securities Fraud Subcommittee: Co–chair
  • ABA Upjohn Task Force: Co–chair 
  • ABA White Collar Committee: Criminal Justice Section and Parallel Proceedings Task Force, Member
  • Business Development and Acceptance Committee: Member

Tom’s Insights

Firm News | 8 min read | 08.15.24

The Best Lawyers in America 2025 Recognizes 42 Crowell & Moring Attorneys, Three Selected as Lawyer of the Year

Washington – August 15, 2024: The 2025 edition of The Best Lawyers in America® has recognized 42 Crowell & Moring lawyers as "Best Lawyers" and 29 lawyers as “Ones to Watch.”...

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