Stephen M. Hauss

Selected Public Matters

• FIFA Investigation – Represented the Fédération Internationale de Football Association (FIFA), international soccer’s governing body, in connection with investigations by the U.S. Department of Justice and the Office of the Attorney General of Switzerland into allegations of bribery and corruption by former high level soccer officials. The New York Times described the matter as “one of the most complicated international white collar cases in recent memory.”
• State of Florida v. Robert K. Kraft – Defended Robert Kraft, the owner of the NFL’s New England Patriots, in connection with criminal charges brought against him by the State of Florida.  Successfully obtained an order of suppression, throwing out unconstitutionally obtained video evidence, resulting in all charges being dropped by the State.
• United States v. McDonnell – Defended Maureen McDonnell, former First Lady of Virginia, in a federal criminal case charging Mrs. McDonnell and her husband, former Virginia Governor Robert McDonnell, with public corruption, extortion, obstruction of justice, and bank fraud. Post trial and on appeal, the First Lady’s conviction for obstruction was dismissed with prejudice by the trial judge and her other convictions, along with the former Governor’s, were thrown out by the U.S. Supreme Court.  The Department of Justice subsequently dismissed with prejudice all charges against the Governor and Mrs. McDonnell.
• MrBeast Internal Investigation – Conducted an internal investigation on behalf of MrBeast, the world’s most-watched YouTube brand, into allegations of sexual misconduct, grooming, and other improprieties within the company. Led a team of attorneys that reviewed millions of documents and interviewed dozens of current and former employees, in connection with the preparation of an investigation report finding no basis for the most serious allegations, while identifying isolated issues and areas for improvement.
• United States v. Miles Guo, et al. – Represented co-defendant Kin Ming Je in a criminal prosecution brought by the U.S. Attorney’s Office for the Southern District of New York, alleging a complex scheme to defraud investors out of more than $1 billion. The indictment charges the defendants with various RICO, wire fraud, securities fraud, bank fraud, and money laundering charges.
• IPIC and Aabar v. Goldman Sachs – Represented two Abu Dhabi sovereign wealth funds, the International Petroleum Investment Company (IPIC) and Aabar Investments, in a multi-billion dollar lawsuit against Goldman Sachs. The lawsuit alleges that Goldman Sachs conspired with others to bribe IPIC’s and Aabar’s former executives as part of a conspiracy to steal billions of dollars from Malaysia’s 1MDB fund.
• 1MDB Civil Forfeiture Actions – Represented Mubadala Development Company, one of the United Arab Emirate’s largest sovereign wealth funds, in connection with civil forfeiture actions filed by DOJ against a Malaysian businessman named Jho Low, with whom Mubadala has various joint ventures, relating to charges that Jho Low assisted various high-level Malaysian government officials to illegally divert several billions of dollars from the Malaysian sovereign wealth fund 1MDB for their personal use. According to DOJ, this case is the largest action ever brought under the Kleptocracy Asset Recovery Initiative.
• ENRC Investigation – Represented Eurasian Natural Resources Corporation (ENRC), ENRC, a global mining conglomerate, in connection with a UK Serious Fraud Office (SFO) investigation into alleged bribery involving the company’s Kazakh and African operations. ENRC was listed on the London Stock Exchange, but de-listed in part as a result of the SFO’s investigation.  Also represented two former executives at the heart of the investigation.  This investigation is classified as one of the SFO’s “blockbuster” cases for which HM Treasury granted additional funding.  
• Lava Jato (“Operation Wash”) Investigation – Represented Trafigura, the world’s third largest commodity trading company, in connection with allegations that a member of its management board was involved in bribery and money laundering at Brazilian state-run oil company Petroleo Brasileiro SA (Petrobras). The executive was arrested after a former Petrobras executive told investigators that he paid more than $800,000 in bribes.  These allegations are related to the Lava Jato scandal in Brazil.
• PDVSA US Litigation Trust v. Lukoil Pan Americas, LLC, et al. – Obtained dismissal of an antitrust action against our client, Trafigura, by a trust purporting to represent the interests of Venezuelan government entities including the state-owned oil company, Petróleos de Venezuela, S.A. (PDVSA).
• United States v. Megaupload & Kim Dotcom – Represented Megaupload Limited and Kim Dotcom in the largest prosecution of alleged criminal copyright infringement ever brought by the U.S. Department of Justice. DOJ has accused Megaupload, Dotcom, and others of running an international organized criminal enterprise allegedly responsible for massive worldwide online piracy of numerous types of copyrighted works, purportedly generating more than $175 million in criminal proceeds and causing more than half a billion dollars in harm to copyright owners.
• AIG False Claims Act Lawsuit – Obtained a dismissal with prejudice on behalf of American International Group (AIG), one of the world’s largest insurance companies, in a federal False Claims Act lawsuit alleging that AIG made false statements regarding its former subsidiaries, the American Life Insurance Company and American International Assurance Limited. Also represented AIG in a federal lawsuit against the New York State Department of Financial Services and its Superintendent alleging that the Department’s interpretation of the New York Insurance Law was unconstitutional under the Due Process and Commerce Clauses, as well as the First Amendment.
• Congressional Investigation of Former Acting IRS Commissioner Steven Miller – Represented Steven Miller, former Acting Commissioner of the Internal Revenue Service, in connection with investigations by the House Oversight Committee, Senate Finance Committee, Senate Permanent Subcommittee on Investigations, and DOJ of alleged targeting of conservative groups by the IRS.
• Sheikh et al. v. Ministry of the Interior of the Republic of Sudan et al. – Obtained a published decision from a unanimous panel of the D.C. Circuit, reversing a district court that had refused, on statute-of-limitations grounds, to enter a default judgment against Iran for its role in sponsoring Al Qaeda’s attack that killed the family member of our clients – alongside scores of others – working at the U.S. Embassy in Kenya in 1998.
• Kurdistan Victims Fund et al. v. Kurdistan Regional Government et al. – Successfully defended Kurdish businessman Sheikh Baz Karim Al-Barzanji, obtaining dismissal of a lawsuit asserting state and federal claims for alleged human rights abuses and corruption.
• United States v. Nadarajah – Defending Jeyakumar Nadarajah, the former head of the U.S. Treasuries trading desk at TD Securities, in a criminal prosecution brought by the U.S. Department of Justice alleging an illegal spoofing scheme.
• PJSC Commercial Bank PrivatBank v. Igor Valeryevich Kolomoisky, et al. – Representing PrivatBank,, the largest commercial bank in Ukraine, in a civil litigation in Delaware Chancery Court against the bank’s former owners.
• In re: North Sea Brent Crude Oil Futures Litigation – Obtained a dismissal on behalf of Trafigura, the world’s third largest commodity trading company, in a multi-district class action lawsuit alleging manipulation of the benchmark price for Dated Brent Crude Oil drawn out of the North Sea.
• Puerto Rico Electric Power Authority Class Action – Defending Trafigura in a RICO class action lawsuit in Puerto Rico, alleging an extensive fuel oil fraud scheme. According to the lawsuit, the Puerto Rico Electric Power Authority (PREPA) colluded with some of the world’s largest fuel suppliers and took kickbacks, in exchange for accepting millions of barrels of fuel oil that did not meet contract requirements or federal environmental standards.  The plaintiffs are seeking damages in excess of $1 billion.
• Dubai Ports World Arbitration – Obtained a settlement for Dubai Ports World in in a dispute involving an investment treaty arbitration and two contract arbitrations with the Republic of Yemen and the state-owned Yemen Gulf of Aden Ports Corporation.
• Investigation of Net 1 – Represented Brian Mosehla, a member of the board of directors of Net 1 UEPS Technologies, Inc., in parallel FCPA investigations by DOJ and the SEC.  The investigations focused on whether Net 1 violated the FCPA by engaging in a scheme to make corrupt payments to South African officials in connection with securing a contract with the South African Social Security Agency to provide social welfare and benefits payments.  DOJ and the SEC formally dropped their investigations, bringing no charges against Mr. Mosehla or Net 1.

Selected OFAC Sanctions Matters

• Represented global mining company in successfully obtaining the removal of its South American subsidiaries from OFAC’s Specially Designated Nationals and Blocked Persons List (the SDN List).
• Defended a multinational commodities trading company in investigations by the U.S. Department of Justice, the U.S. Attorney's Office for the Southern District of New York, and the Manhattan District Attorney's Office of alleged violations of U.S. trade sanctions on doing business in Iran, Sudan and Cuba.
• Advised foreign government ministry on issues related to application of U.S. sanctions law.
• Representing sanctioned energy company in connection with applying for removal from the OFAC SDN List.
• Representing family members of sanctioned oligarch in connection with applying for removal from the OFAC SDN List.
• Advising multinational oil company in connection with application for specific OFAC license related to acquisition of sanctioned oil and gas assets.
• Prepared and submitted application for specific OFAC license on behalf of U.S. company seeking to enforce judgment against sanctioned entity in Zimbabwe.
• Advised multinational company in connection with sanctions issues related to enforcement of judgment against Iranian oil company.
• Provided Iran sanctions compliance advice to one of the largest bulk material supply companies in the Middle East.
• Advised an international trading company on various compliance issues related to transactions involving Russian counterparties.
• Advised a global shipbuilding company on compliance issues related to their business with sanctioned countries, including Cuba and Sudan.
• Assisted a Swiss chemical company in applying to OFAC for the release of funds that had been blocked pursuant to the Russian sanctions regime.
• Advised sovereign wealth fund on issues related to U.S. trade sanctions.
• Provided sanctions advise to a Russian client in connection with a long running dispute against an oligarch named to OFAC’s Specially Designated Nationals List.
• Advised a global logistics company based in the Middle East regarding the application of Global Magnitsky Sanctions.
• Advised an online services provider in connection with potential violations of U.S. sanctions related to the Crimea region.
• Advised an international food company regarding the application of U.S. sanctions against Cuba.

Selected FARA Matters

• Successfully defended lobbyist in criminal investigation by the Counterintelligence and Export Control Section of the Department of Justice’s National Security Division into alleged violations of FARA registration requirements.
• Represented prominent U.S. law firm in challenging registration determination by U.S. Department of Justice.
• Advised major multinational conglomerate on FARA issues related to criminal bribery investigation and prosecution.
• Represented oil company in connection with challenge to registration determination by U.S. Department of Justice.
• Advised foreign embassy on FARA issues.
• Advised head of foreign state-owned bank on various FARA-related issues.
• Advised Middle Eastern logistics company on FARA registration requirements.

Selected Bribery/Corruption Matters

• Represented an international maritime company in a U.S. investigation and prosecution alleging corruption in connection with major transactions in East Africa.
• Conducted an internal investigation in Russia of alleged FCPA violations and accounting fraud.
• Represented a foreign housing corporation in connection with investigations into allegations that international banks bribed the corporation’s former treasurer in order to secure interest rate swaps that resulted in hundreds of millions in losses for the housing corporation while earning millions in fees for the banks.
• Represented multinational company in relation to investigation by Maltese authorities into allegations of bribe payments to executives of state-owned utility company.
• Conducted an internal investigation in Thailand of alleged FCPA violations.
• Conducted an internal investigation in the Middle East of alleged FCPA violations, money laundering, trade sanctions, and fraud.
• Defense of a former senior campaign official in an investigation of alleged political corruption in New York City by the U.S. Attorney’s Office for the Southern District of New York.
• Representation of global manufacturing and distribution company in internal investigation of alleged FCPA violations in China.
• Representation of global manufacturing and distribution company in internal investigation in Mexico.
• Investigated allegations of bribery and fraud in connection with client’s operations in India.
• Advised global construction company on issues related to the FCPA.

Other Selected Matters

• Obtained an order granting Section 1782 discovery on behalf of a multinational company for use in a foreign proceeding.
• Obtained dismissal of state regulatory investigation on behalf of pharmaceutical company.
• Represented a Swiss bank in an investigation and prosecution by the U.S. Attorney’s Office for the Southern District of New York for alleged conspiracy to facilitate tax evasion by U.S. taxpayers.
• Defense of one of the world’s largest insurance companies in a criminal investigation by the Manhattan District Attorney’s Office for allegedly making false submissions to regulators.
• Represents an executive of a leading health care company in a False Claims Act investigation by the U.S. Department of Justice and related civil litigation.
• Defense of a large insurance company in an investigation by the New York Attorney General’s Office regarding an alleged failure to pay state taxes.
• Represented an individual in a voluntary disclosure to the IRS in connection with undisclosed income deposited into a Swiss bank account.
• Defended a financial advisor in a prosecution by the U.S. Department of Justice for various conspiracies involving tax evasion, wire fraud, and other financial frauds.
• Representation of an executive of a venture capital firm in an extortion investigation by the U.S. Department of Justice against a third party.
• Defended a multinational commodities trading company in CFTC and FSA investigations of alleged market manipulation in the energy market.
• Advised a sovereign wealth fund in connection with acquisition of company subject to Committee on Foreign Investment in the United States (“CFIUS”) review process.
• Advised sovereign wealth fund in connection with litigation risks associated with investment in technology company.
• Represented supplier to U.S. military in Freedom of Information Act dispute.
• Represented a national trade association in connection with claims for defamation, tortious interference, and unfair competition against a competitor.
• Represented a stockholder of a telecommunications company in connection with a lawsuit to prevent acquisition of the company below fair market value.
• Represented a biotechnology company in the appeal of a district court’s denial of an anti-suit injunction.
• Represented a multinational telecommunications company in the appeal of a district court’s issuance of a temporary restraining order and preliminary injunction.
• Advised a global investment company on possible claims for defects in properties owned by a joint venture in which the company was a participant.
• Advised group of multinational companies in connection with U.S. Department of Justice’s Antitrust Division’s business review letter process.

• Brazil Practice
• Crisis Law & Strategy Group
• False Claims Act
• Government & Regulatory Litigation
• Investigations, Government Enforcement & White Collar Criminal Defense Practice
• Middle East & North Africa Practice
• Russia Disputes Practice
• Securities Litigation
• Sovereign Wealth Fund Litigation
• Sports Litigation
• Transnational Litigation

• Harvard Law School
  (J.D., cum laude, 2006)
• University of California, Los Angeles
  (B.A., Political Science, summa cum laude, 2003)

• The District of Columbia Bar
• The State Bar of California
• United States Court of Appeals:
  • Fourth Circuit
  • District of Columbia Circuit
• United States District Courts:
  • District of Columbia
  • Central District of California

• Law Clerk to the Hon. F. Dennis Saylor IV:
  • United States District Court for the District of Massachusetts, 2006-2007
    
• Deputy District Attorney:
  • Los Angeles County District Attorney’s Office, 2009-2011

• Lawdragon 500 Leading Global Entertainment, Sports & Media Lawyers, Litigation - White Collar, Investigations, Sports, 2025
• Lawdragon 500 Global Leaders in Crisis Management, 2025
• Lexology Index, Investigations – Future Leaders, 2025
• Who’s Who Legal, Investigations – Future Leaders, 2018-2021, 2023-2024
• Super Lawyers, Rising Star, 2021
• Who’s Who Legal, Commercial Litigation – Future Leaders, 2021
• Who’s Who Legal, Litigation – Future Leaders, 2019-2020
• Global Investigations Review, 40 Under 40: The World’s Leading Young Investigations Specialists, 2017
• Law360, Rising Star: White Collar, 2016
• The American Lawyer, Transatlantic Rising Star, 2016

• Panel Member, National Security Cases and FARA, National Association of Criminal Defense Lawyers White Collar Conference, (October 2023).
• Webinar, Planning for Default as a Russian Sovereign or Corporate Bondholder, (March 2022).
• Firm Memorandum, What Companies Need to Know About the U.S. Sanctions Against Russia, (March 2022).
• Firm Memorandum, New “Beneficial Owner” Requirements Under the Corporate Transparency Act, (January 2021).
• Firm Memorandum, US Outlook: Top Questions About Criminal And Internal Investigations Following The Coronavirus Outbreak, (April 2020).
• Firm Memorandum, In Blow to U.S. Government, Court Overturns Former Alstom Executive's FCPA Convictions, (February 2020).
• Firm Memorandum, CFIUS: What the Recent Regulations Mean for Private Equity, (February 2020).
• Firm Memorandum, OFAC Sanctions Rosneft's Swiss Trading Arm for Operating in Venezuela's Oil Sector, (February 2020).

• Life Fellow, American Bar Foundation
• Member, American Bar Association
  • Criminal Justice Section
  • Global Anti-Corruption Committee
  • International White-Collar Committee
• Member, International Bar Association
• Member, American Society of International Law
• Volunteer, Clemency Project 2014