Clients say Mr. Greenburg is "a very bright, thoughtful and practical adviser" and praise his "extraordinarily good judgment and very effective way of getting to the right results."Chambers USA 2018

Douglas N. Greenburg

Washington, D.C.
  • 555 Eleventh Street, NW
  • Suite 1000
  • Washington, D.C. 20004-1304
  • USA

Doug Greenburg is a partner in the Washington, D.C. office and the local Chair of the Litigation & Trial Department. He previously served for five years as a Vice Chair of the Global Litigation Department. His practice focuses on internal corporate investigations, white collar criminal defense, and SEC enforcement proceedings. Mr. Greenburg has extensive experience representing clients in connection with alleged violations of the Foreign Corrupt Practices Act (FCPA), economic sanction and export control violations, money laundering, securities fraud and complex regulatory matters. He counsels clients worldwide on compliance with US laws and advises US clients on domestic compliance issues arising from international operations.

Mr. Greenburg has particular experience representing public companies, and their boards and audit committees, in connection with high-stakes law enforcement and regulatory matters. He also represents leading private equity firms, investment banks, and other companies throughout the world in connection with compliance issues arising in M&A and capital markets transactions and global operations. He regularly represents companies and executives based outside the United States and has extensive expertise in cross-border investigations.

From 2003-2004, Mr. Greenburg served on the staff of the National Commission on Terrorist Attacks Upon the United States. During this time, he investigated the financing of al Qaeda and the 9-11 terrorist attacks and the effectiveness of US efforts to identify and disrupt terrorist financing, and co-authored the Commission staff’s acclaimed "Terrorist Financing Monograph.”

In 1995 and 1996, Mr. Greenburg served as an attorney with the Securities & Exchange Commission’s Division of Enforcement. He previously served as a law clerk for Judge Alan E. Norris, United States Court of Appeals for the Sixth Circuit.

Mr. Greenburg is recognized as a leading White Collar & Criminal Investigations lawyer by Chambers USA 2014-2018. He is recommended for his white-collar criminal defense practice in The Legal 500 US 2016.

Recent matters that Mr. Greenburg has led or co-led include:

  • Successfully negotiating on behalf of a US life sciences company a non-prosecution agreement with DOJ and an SEC settlement to resolve major FCPA investigations concerning Russia, Vietnam, and Thailand
  • Conducting an internal investigation of potential FCPA violations in Nigeria and Kazakhstan on behalf of the audit committee of a US company in the oil and gas industry, resulting in a resolution on favorable terms with the DOJ and SEC
  • Defending a leading global oilfield services company in a grand jury investigation of alleged violations of the US economic sanctions on Iran and Sudan
  • Obtaining a declination of prosecution from DOJ related to alleged FCPA violations in Eastern Europe by a US-based manufacturer 
  • Representing a senior officer of one of the world’s largest banks in an anti-money laundering review related to foreign correspondent banking 
  • Representing a Middle East affiliate of a major global bank in a US forfeiture action brought under the interbank seizure provisions of the USA PATRIOT ACT
  • Defending a major global corporation in the oil and gas industry in an SEC investigation related to three financial restatements 
  • Representing a publicly traded REIT in connection with a DOJ and SEC FCPA investigation related to Mexico arising from the high-profile allegations against Walmart in Mexico 
Thought Leadership
  • "Three Practical Steps to Managing FCPA & Anti-Corruption Risks," June 2014
  • "Bank Programs to Interdict Corruption-Related Money Laundering," October 2011 
  • "Scope of US Sanctions Against Libya and Syria Defined Further by Treasury Department General Licenses," September 12, 2011 
  • "US and EU Sanctions Continue to Evolve in Response to Events in the Middle East and North Africa," September 1, 2011 
  • "Prosecutors Without Borders: Emerging Trends In Extraterritorial Enforcement," April 29, 2011 
  • "Broad US and UN Sanctions Freeze Libyan Assets and Restrict Dealings with the Qadhafi Regime," February 28, 2011 
  • "A Tale of Two Clawbacks: The Compensation Consequences of Misstated Financials," August 10, 2010 
  • "Reining in the Foreign Corrupt Practices Act: The Supreme Court Ignores a Perfect Opportunity, July-August 2010 
  • "US Sentencing Commission Approves Proposed Amendments to Federal Sentencing Guidelines for Organizations and Expands and Clarifies the Role of Corporate Compliance and Ethics Programs in Organizational Sentencing," May 14, 2010
  • "Companies Doing Business With Iran and Other US-Sanctioned Countries Face Expanding Risks of Government Investigations and Enforcement," March 12, 2010 
  • "US Department of Justice Announces Stepped-Up Criminal Enforcement of Foreign Corrupt Practices Act Against Pharmaceutical Industry, November 24," 2009 
  • White Collar and Government Investigations Newsletter, Issue 1, Summer 2007 
  • "Special Measures Under Section 311 of the USA Patriot Act," June 2007 
  • "Financial Institutions in the Cross-Hairs: Lessons from Recent Major Anti-Money Laundering Enforcement Cases," March 2006
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