David A. Last
Partner
David A. Last’s practice focuses on enforcement and litigation, including government and internal investigations, white collar criminal defense of companies and individuals in a wide range of high-stakes domestic and international enforcement actions, crisis management, and trials with a particular focus on complex cross-border matters such as those involving the Foreign Corrupt Practices Act (FCPA).
David brings extensive experience in leading complex white collar criminal investigations and litigation matters both in private practice and during his 17 years as a federal prosecutor for the Department of Justice, where he investigated and conducted trials related to various subject matters, including foreign bribery, money laundering, fraud, and tax offenses.
Prior to joining Cleary, David served as the Chief of the FCPA Unit at the Department of Justice, where he oversaw all FCPA-related investigations, prosecutions, corporate resolutions, trials, and compliance monitorships in the United States. Under his leadership, the FCPA Unit investigated over 200 matters involving the FCPA, money laundering, wire fraud, and other corruption-related offenses, encompassing every significant industry sector and geographic region. As a prosecutor and supervisor in the FCPA Unit, David led and oversaw many of the DOJ’s most high-profile and significant matters, including one of the largest coordinated FCPA resolutions in history. David also played a key role in shaping major corporate criminal enforcement policies. He also reviewed and evaluated the compliance programs of numerous companies under investigation by the DOJ. As Chief of the FCPA Unit, David also collaborated extensively with domestic regulators such as the SEC, CFTC, and Federal Reserve, as well as international law enforcement authorities in the United Kingdom, France, Switzerland, Brazil, and Mexico, among numerous others.
In addition to his leadership roles at DOJ, David is also a seasoned trial lawyer, having personally tried more than 40 cases to verdict and supervised some of the most complex white-collar and foreign bribery related investigations and trials in the country. For over a decade, David served as an Assistant U.S. Attorney in Washington, D.C., where he investigated and prosecuted a wide variety of white-collar criminal cases, including financial fraud, public corruption, wire fraud, money laundering, bank fraud, tax evasion, and Travel Act violations, among other criminal cases. David also investigated a number of matters related to claims under the False Claims Act.
Since joining Cleary, David has worked with clients on a broad spectrum of criminal and civil litigation issues, including internal investigations and representations related to anti-bribery and corruption, False Claims Act, cyber fraud, and sanctions. David also represents public and private companies, as well as individual executives, in matters before the DOJ, the SEC and other regulators. He also frequently advises on the development of compliance and integrity programs and counsels clients in advance of strategic transactions.
David joined the firm as a partner in 2023.
Notable Experience
Notable Experience
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Multinational medical equipment company in an internal investigation and FCPA investigation by the DOJ.
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Global mining and metals company in connection with an internal investigation and FCPA investigation by the SEC.
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Fintech company in connection with DOJ grand jury investigation related to potential sanctions violations.
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International financial institution and U.S. broker-dealer in an internal investigation related to cyber fraud.
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Multinational products company in an internal investigation of potential fraud and corruption related to conduct in Argentina.
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Multinational technology company in connection with an FCPA investigation by the SEC.
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Latin American paper company in connection with a DOJ investigation into allegations of procurement fraud and corruption.
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Global investment firm in connection with False Claims Act investigation related to portfolio company.
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Multinational automotive manufacturer in connection with DOJ consumer products investigation.
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Global products company in an internal investigation regarding whistleblower allegations concerning accounting irregularities and third-party payments in the Middle East.
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International health care and personal products company in an internal investigation of potential fraud and corruption related to conduct in Mexico.
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Latin American mining company in connection with a global anti-corruption compliance review and risk assessment.
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International telecommunications company in connection with review and assessment of its global anti-corruption program, compliance policies, and procedures.
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Anti-corruption and bribery compliance advice to a Dutch multinational corporation related to anti-corruption policies and procedures, including due diligence and post-transaction integration.
SELECTED ACTIVITIES
trigger- Board Member, Volunteer Legal Advocates (formerly D.C. Volunteer Lawyers Project)
- Adjunct Professor, Georgetown University Law Center
Publications
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DOJ Releases First Department-Wide Corporate Enforcement Policy
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DOJ Announces Record-Breaking $6.8 Billion in False Claims Act Recoveries for Fiscal Year 2025
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Whistleblowing in Focus: Recent Developments, Emerging Issues, and Considerations for Companies
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A Tale of Two Investigations: The Value of Voluntary Disclosure
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Enforcement Countdown: Is DOJ Ready for the Bulk Data Rule “Grace Period” to End?
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DOJ National Security Division Issues First Declination Under Merger-Related Safe Harbor Provisions
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Supreme Court Upholds Expansive Reading of Wire Fraud Statute
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The FCPA Executive Order: What to Expect and Why Compliance Matters
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DOJ National Security Division Issues Second Declination Under Corporate Enforcement Policy
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California AG Advises Businesses It Is Illegal to Bribe Foreign Officials
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New Anti-Corruption Taskforce Announced by Authorities in the UK, France, and Switzerland
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DOJ Announces New Pilot Program Aimed at Uncovering Corporate Misconduct
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DOJ Announces New White Collar Whistleblower Program and Increased Focus on the Use of AI
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2023 Year-in-Review: Developments and Trends in White Collar Enforcement Litigation
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Congress Passes Foreign Extortion Prevention Act to Prosecute Corrupt Foreign Officials
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DOJ New Safe Harbor Policy for Voluntary Self-Disclosures in M&A
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DOJ Announces Additional Guidance on Voluntary Self-Disclosure in M&A Context
Events
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March 10, 2026
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December 3, 2025
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May 7, 2025
20th Annual FCPA & Anti-Corruption for the Life Sciences Industry
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April 9, 2025
PLI’s The Foreign Corrupt Practices Act and International Anti-Corruption Developments 2025
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January 22, 2025
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December 4, 2024
America Conference Institute’s International Conference on the FCPA
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October 24, 2024
Latin Lawyer and GIR Live: Anti-Corruption and Investigations Brazil 2024
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June 14, 2024
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May 10, 2024
19th Annual FCPA & Anti-Corruption for the Life Sciences Industry
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March 15, 2024
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March 13, 2024
ACI’s Mexico Summit on Anti-Corruption & Compliance Programs
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December 14, 2023
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November 30, 2023
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November 9, 2023
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October 29, 2023
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October 17, 2023
Latin Lawyer and GIR Live: Anti-Corruption and Investigations Brazil 2023
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September 7, 2023