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Paul M. Rosen

Partner

prosen@crowell.com
Phone: +1 213.443.5577
515 South Flower St., 40th Floor
Los Angeles, CA 90071-2201

Paul Rosen, a former federal prosecutor and chief of staff at the Department of Homeland Security, is a partner in the firm’s White Collar & Regulatory Enforcement, Privacy & Cybersecurity, and Government Contracts groups.

With more than a decade of legal, policy, and management experience across all three branches of government, Paul represents corporate and individual clients in connection with federal and state government investigations and enforcement actions, internal investigations, cybersecurity and data privacy, immigration and cross border issues, national security, and litigation matters. Paul also counsels clients on all aspects of managing a crisis to mitigate legal and reputational exposure in criminal, civil, regulatory, administrative, transactional, and Congressional matters. In addition, Paul counsels businesses on both domestic and international privacy compliance matters, including the EU General Data Protection Regulation (GDPR), and the California Consumer Privacy Act (CCPA).

Criminal, Internal Investigations and Related Representative Matters

  • Securing a declination from DOJ's Fraud Section of a senior executive at a large global financial institution in connection with a criminal investigation of a complex foreign exchange (FX) transaction.
  • Obtaining a declination from DOJ’s Fraud Section for a pool of employees of a large government contractor that manufactures components for aerospace, transportation, energy and industrial sector clients.  
  • Representation of German-based individuals, including a senior in-house attorney, in connection with the Environmental Protection Agency (EPA) and DOJ’s criminal investigation into automobile manufacturing practices that circumvented emissions standards and tests.
  • Representation of a broker at a global financial services company in connection with a Securities and Exchange Commission (SEC) insider trading investigation. 
  • Representation of a London-based employee of global financial institution in connection with a Financial Industry Regulatory Authority (FINRA) Enforcement Department investigation into the marking of credit default swaps.
  • Representation of a government contractor with worldwide operations facing a various government investigations, including by a Congressional committee, in to alleged improper activities in the course of executing its contract.
  • Representation of the Regents of the University of California in procurement fraud-related litigation and investigative matters in connection with alleged misconduct by a former university employee and former university contractor.
  • Representation of multiple members of the Board of Directors of a Silicon Valley-based Internet health care start-up in conducting an internal investigation into alleged misconduct by the Founder/CEO, resulting in the CEO’s removal from the company and the Board.
  • Conducting an internal investigation for a managed care provider in the health care industry in connection with #MeToo related reports of employee and sexual misconduct.
  • Advising a national railroad in a Transportation Security Administration (TSA) investigation of regulatory violations in connection with a railroad security incident. 
  • Representing an Asia-based electronics manufacturer in connection with a U.S. Customs and Border Protection (CBP) investigation into import duties and related trade matters.
  • Representation of a former pharmaceutical company employee in connection with a multi-agency federal and state government investigation.
  • Representation of a Mexican-based logistics company in connection with a cross-border smuggling investigation by the U.S. Attorney’s Office, ICE Homeland Security Investigations (HSI), and U.S. Customs and Border Protection (CBP).
  • Representation of Mexican subsidiary of a U.S. logistics company in connection with a Foreign Corrupt Practices Act (FCPA) investigation.

Cybersecurity and Privacy Representative Matters

  • Representation of a Fortune 100 global multimedia company in connection with cybersecurity and privacy compliance, incident response planning and preparation, and legal obligations in connection with various cybersecurity and privacy incidents.
  • Representation of a municipality in connection with cybersecurity and privacy compliance, data security and storage, and related legal risks. 
  • Counseling a global technology company that suffered a ransomware attack and advising on the potential legal and business impacts associated with the attack.
  • Representation of an American global automotive parts supplier with regard to cybersecurity and privacy requirements under the California Consumer Privacy Act of 2018.
  • Representation of a government contractor in response to a ransomware attack to address the crisis, mitigate legal risk, engage law enforcement, and appropriately report the incident. 
  • Counseling a Fortune 25 global telecommunications provider in connection with product development and compliance with legal requirements under the Communications Assistance to Law Enforcement Act (CALEA), Wiretap Act, Stored Communications Act, Electronic Communications Privacy Act (ECPA), and related laws.
  • Counseling and leading breach response and law enforcement engagement for an organization in the critical infrastructure sector in response to a successful phishing attack of a senior executive that exposed sensitive information in a business email compromise scheme. 

CFIUS, Security, and Related Counseling 

  • Representation of a leading automobile parts manufacturer in a transaction before the Committee on Foreign Investment in the United States (CFIUS), resulting in CFIUS’ approval of a complex global transaction. 
  • Advising a former cabinet officer in connection with testimony before Congressional committees investigating activities associated with the 2016 U.S. presidential election.
  • Counseling a trade association to facilitate the protection of its intellectual property in connection with enforcement matters by CBP. 
  • Advising a company that facilitates the DHS, CBP, and TSA trusted traveler programs in regulatory and legal matters.
  • Counseling an Asia-based indirect air carrier on TSA regulatory compliance requirements.
  • Advising a Fortune 10 global technology company on appropriate security procedures and processes to safeguard datacenters that house servers and other sensitive equipment.

Government Experience

Paul’s more than ten years of government experience includes the following:

  • Department of Homeland Security—Chief of Staff (2015-2017); Deputy Chief of Staff (2014-2015); Senior Counselor (2014); Chief of Staff, U.S. Immigration and Customs Enforcement (2013-2014)
  • Department of Justice: Criminal Division—Trial Attorney, Fraud Section (2011-2013)
  • Department of Justice: United States Attorney's Office—Eastern District of Virginia: Special Assistant U.S. Attorney (2010-2011)
  • Department of Justice: Criminal Division—Counsel to the Assistant Attorney General (2009-2010)
  • United States Senate—Counsel to Senator Joseph R. Biden, Jr., Senate Judiciary Committee (2006-2009)
Just prior to joining Crowell & Moring, Paul served in several senior leadership roles within the DHS, including most recently as chief of staff. In this role, Paul managed for the secretary the operational, organizational, policy, and legal needs for the third-largest department of government, with 230,000 employees, a $60 billion budget, and 22 component agencies. Among the agencies he oversaw included the National Protection and Programs Directorate, Customs and Border Protection, Secret Service, Transportation Security Administration, Immigration and Customs Enforcement, Domestic Nuclear Detection Office, Federal Emergency Management Agency, and U.S. Coast Guard, among others.

Paul supervised DHS’s response to some of the most sensitive and complex challenges facing the government, including civil and criminal investigations and litigation, regulatory matters, Congressional oversight, public relations, and crisis management. He advised the secretary and the White House on counterterrorism; cyber, data security, and incident response; border, aviation, and maritime security; trade and customs violations; immigration and visa policies; nuclear weapons detection; national security risks associated with foreign investments in connection with the Committee on Foreign Investment in the United States, or CFIUS; federal disaster response; critical infrastructure; financial crimes; and other criminal law enforcement matters.

In recognition of his work, the secretary awarded Paul the DHS Distinguished Service Medal, the highest honor bestowed by the secretary to recognize exceptional and transformational public service. He is also a recipient of the Director’s Distinguished Service Award from the Secret Service.

Paul has worked extensively with other federal agencies, including the Departments of Justice, Treasury, and Defense, the FBI, and intelligence agencies on some of the most highly publicized global security and terrorist threats, including:
  • Significant cybersecurity events, such as hacks of the government agencies and systems, attacks on critical infrastructure, and related cyber crises.
  • The government’s response to the surge of unaccompanied children and families crossing the U.S. border in 2014.
  • The Orlando, Brussels, Chattanooga, San Bernardino, Paris, and Egypt Air terror attacks.
  • Manned and unmanned aerial vehicles, or drones, penetrating restricted airspace in Washington, D.C. and elsewhere.
  • National security threats posed by the Zika and Ebola virus outbreaks.
  • The investigation and extradition of high profile international fugitives from a variety of countries.
  • The threat posed by ISIS and U.S. efforts to disrupt their activities overseas and in the United States.

At DHS, Paul also served as deputy chief of staff and senior counselor, and chief of staff at U.S. Immigration and Customs Enforcement.

In addition to his work on national and border security, Paul served for more than four years at the U.S. Department of Justice, including as a federal prosecutor in the U.S. Attorney’s Office for the Eastern District of Virginia and in the Department of Justice Criminal Fraud Section. He prosecuted financial crimes by companies and individuals, including securities fraud, bank and mortgage fraud, FCPA, money laundering, insider trading, corruption, bankruptcy fraud, and government and procurement fraud. During this time, he:

  • Led an international FCPA investigation of a Fortune 100 global technology company for alleged payment of bribes to foreign government officials across four continents.
  • Led the investigation of a $28 million real estate developer mortgage fraud scheme concerning activities that contributed to the 2008 financial crisis.
  • Co-led the criminal investigation into potential insider trading and securities fraud of individuals and a Fortune 200 technology company.
  • Co-led the investigation and prosecution of individuals for masterminding a sophisticated nationwide foreclosure-rescue and bankruptcy fraud scheme.
  • Co-led the investigation of a major bank failure, which after trial resulted in convictions for conspiracy, securities fraud, and other corporate fraud.
In addition to working with federal partners, during his time in government Paul also worked with state and local law enforcement and State Attorneys General on a range of enforcement related matters.

In recognition of his work, in 2012 the Council of Inspectors General on Integrity and Efficiency recognized Paul with its Investigations Award for Excellence.

From 2006 to 2009, Paul served as counsel to then-U.S. Senator Joseph R. Biden, conducting oversight investigations and advising on civil and criminal law policies and legislation confronting the Senate Judiciary Committee, including intellectual property rights, antitrust and bankruptcy law, narcotics and firearms laws and the federal sentencing guidelines. He also served as Staff Director to the Senate Caucus on International Narcotics Control. Prior to that, Paul was a law clerk to the Honorable Gary Allen Feess, U.S. District Judge for the Central District of California.

Paul is a guest lecturer and speaker at Harvard’s John F. Kennedy School of Government and at the University of Southern California’s Gould School of Law and undergraduate college. He is also a Homeland Security Project fellow at Harvard's Belfer Center for Science and International Affairs. He is a member of the California Bar and the Pacific Council on International Policy.

Education

  • University of Colorado at Boulder, B.A. (2000) summa cum laude, Phi Beta Kappa
  • University of Southern California, Gould School of Law, J.D. (2005) Order of the Coif

Affiliations

Admitted to practice: California, District of Columbia, U.S. District Court for the Central District of California, U.S. Court of Appeals for the Ninth Circuit

Awards

  • Southern California Super Lawyer in Criminal Defense: White Collar, 2019
  • Law360 Distinguished Legal Writing Award, The Burton Awards, 2018
  • Cybersecurity & Data Privacy Trailblazer, The National Law Journal, 2017
  • Cyber Security Attorney of the Year, Leaders in Law Award, Los Angeles Business Journal, 2017
  • Distinguished Service Medal, U.S. Department of Homeland Security, 2017
  • Director’s Distinguished Service Award, U.S. Secret Service, 2017
  • Investigative Award of Excellence, Council of Inspectors General on Integrity and Efficiency, 2012

Professional Activities and Memberships

  • Contributor, Forbes.com
  • Fellow, Harvard Kennedy School, Belfer Center for Science and International Affairs, The Homeland Security Project
  • Guest Lecturer, "Mitigating and Managing a Crisis," John F. Kennedy School of Government, Harvard University, 2017-2019
  • Pacific Council on International Policy, Member 
  • Board Member, Federal Bar Association, Los Angeles Chapter, 2009-present
  • Co-Chair, Science & Technology Section, Homeland Security Committee, American Bar Association
  • Member, White Collar Crime Committee, American Bar Association
  • Board of Directors, Bet Tzedek Legal Services

View More

"A Deeper Look at Cross-Border Trade Shifts with Mexico," Los Angeles Chamber of Commerce and Global Initiatives Council (August 19, 2020). Moderator: Paul M. Rosen; Council Chair: Nicole Janigian Simonian.
Speech/Presentation
"California Approves Final CCPA Regulations," Privacy Law Alert (August 17, 2020). Contacts: Kristin J. Madigan, CIPP/US, Jeffrey L. Poston, Paul M. Rosen, Jarno Vanto, Maida Oringher Lerner, Lee Matheson, CIPP/US/E/A, CIPM, PCIP
Client Alert / Newsletter
COVID-19 Vaccine Hacking May Prompt Data Security Rethink Law360 (July 24, 2020)
Media Mentions
COVID-19 Investigations Q&A Webinar — “Preparation & Prevention – Addressing and Mitigating Key Investigations Risks in the COVID-19 Era,” Crowell & Moring Webinar (June 24, 2020). Presenters: Stephen J. McBrady, Natalie O. Ludaway, Paul M. Rosen, and Daniel L. Zelenko.
Speech/Presentation
"Senate Judiciary Committee Hearing Highlights COVID-19 Enforcement Trends and Priorities," Government Contracts Bullet Points (June 12, 2020). Contacts: Peter Eyre, Mana Elihu Lombardo, Rebecca Monck Ricigliano, Paul M. Rosen, Gail D. Zirkelbach, Rina M. Gashaw
Client Alert / Newsletter
"DOJ Charges Individual for Using COVID-19 Paycheck Protection Program for Personal Expenses," White Collar Alert (May 27, 2020). Contacts: Mana Elihu Lombardo, Amy Laderberg O'Sullivan, Rebecca Monck Ricigliano, Paul M. Rosen, Gabrielle Trujillo
Client Alert / Newsletter
"Prosecutors in New York and Texas Charge Individuals for Defrauding COVID-19 Relief Programs," White Collar Alert (May 22, 2020). Contacts: Amy Laderberg O'Sullivan, Rebecca Monck Ricigliano, Paul M. Rosen, Daniel L. Zelenko, Laura Schwartz
Client Alert / Newsletter
"COVID-19 Enforcement Actions Surrounding Stimulus Funds," White Collar Alert (May 7, 2020). Contacts: Mana Elihu Lombardo, Amy Laderberg O'Sullivan, Rebecca Monck Ricigliano, Paul M. Rosen, Daniel L. Zelenko, Laura Schwartz
Client Alert / Newsletter
"CARES Act Compliance, Oversight And Investigations: A Basic Checklist For Business," Forbes (April 28, 2020). Author: Paul M. Rosen.
Publication
""Authorized Access": The Supreme Court’s First Foray Into The Computer Fraud And Abuse Act," Litigation Alert (April 22, 2020). Contacts: Stephen M. Byers, Jeffrey L. Poston, Gabriel M. Ramsey, Paul M. Rosen, Joshua M. Rychlinski, Kayvan M. Ghaffari
Client Alert / Newsletter

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Crowell & Moring LLP is an international law firm with more than 500 lawyers representing clients in litigation and arbitration, regulatory, and transactional matters. The firm is internationally recognized for its representation of Fortune 500 companies in high-stakes litigation, as well as its ongoing commitment to pro bono service and diversity. The firm has offices in Washington, DC, New York, Los Angeles, San Francisco, Orange County, London, Brussels, and Shanghai.

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