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Thomas A. Hanusik

Phone: +1 202.624.2530
1001 Pennsylvania Avenue NW
Washington, DC 20004-2595

Tom Hanusik is a partner in Washington D.C. and a member of Crowell & Moring's White Collar & Regulatory Enforcement Group, which Law360 named a "White Collar Group of the Year" in 2012 and one of ten "FCPA Powerhouses" in 2013. Tom is also chair of Crowell & Moring's Investigations practice.

Tom's practice focuses on white collar defense, SEC Enforcement, FINRA Enforcement and internal investigations. He defends publicly traded and privately held companies, senior executives, board members and politicians during internal and government investigations, criminal and civil trials, regulatory enforcement actions, and appeals. Tom has over twenty years of trial and appellate experience. He also leads teams conducting internal investigations on behalf of companies, boards of directors and board committees, as well as advising corporate clients 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 including financial fraud, insider trading, FCPA and Section 5 violations, AML requirements, federal and state tax offenses, public corruption and violations of U.S. export controls and sanctions regulations.

InsideCounsel's "Crisis Rolodex" magazine named Tom one of the "The Best Lawyers to Call in a Worst-Case Scenario" for a white collar investigation in its "Crisis Rolodex" in 2007. In 2013 and 2017, Tom was named to SecuritiesDocket's "Enforcement 40" list of the best and brightest SEC Enforcement attorneys in the industry. Tom is also Chambers ranked in white collar & government investigations where comments about him note, "He is very highly regarded for his extensive knowledge of all white collar matters," for being "very much attuned to which arguments will work," and for always "genuinely having his client's best interests at heart." Tom has also been consistently recognized in The Best Lawyers in America since 2008 in the areas of white collar criminal defense and securities regulation.

Select Representations

  • 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.

Government Service

Tom joined Crowell & Moring after almost 12 years at the DOJ and SEC. While at DOJ, Tom was one of the original prosecutors on the Enron Task Force, where he successfully prosecuted a number of senior Enron executives and external advisers. He was then promoted to assistant chief in the Criminal Division, Fraud Section, where he also served as senior counsel for Securities Fraud. 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 career at both the DOJ and SEC, Tom led, supervised, and coordinated a number of parallel criminal grand jury and civil law enforcement investigations. In addition to the Enron Task Force, Tom was a member of the inter-agency Securities and Commodities Fraud Working Group at DOJ and he was active in DOJ's corporate fraud initiative. Tom has also participated in the negotiation of corporate-level dispositions on behalf of the government, including civil injunctive actions and cease-and-desist proceedings, and criminal deferred-prosecution and non-prosecution agreements.

Just prior to joining Crowell & Moring, Tom led DOJ's prosecution team investigating the abuse of finite reinsurance products in the insurance industry. He also has extensive experience prosecuting criminal and civil cases involving conspiracy, bank fraud, insider trading, money laundering, counterfeiting, identity theft, social security fraud and education loan fraud. He has extensive experience with extradition requests, gathering foreign evidence through Mutual Legal Assistance Treaties (MLATs), and investigating alleged FCPA violations.

Awards and Affiliations

Barrister, Edward Bennett Williams Inn of Court
Duke Law Alumni Association Board of Directors
Assistant Attorney General's Award for Financial Integrity
Letters of commendation from the Attorney General and the FBI Director
Special Achievement Awards and Meritorious Awards for exemplary service
Award for Public Service from the United States Attorney for the Eastern District of Virginia
Chair, Strategic Business Acceptance Subcommittee
Co-chair, ABA National Institute on Securities Fraud
Co-chair, ABA Securities Fraud Subcommittee
Co-chair, ABA Upjohn Task Force
Member, ABA White Collar Committee, Criminal Justice Section and Parallel Proceedings Task Force
Member, Business Development and Acceptance Committee


  • Fordham University, A.B. (1986)
  • Duke University School of Law, J.D. (1990)


Admitted to practice: District of Columbia, New York, and numerous federal courts

View More

"FCPA Guidance Update: DOJ and SEC Release Second Edition of Resource Guide to the U.S. Foreign Corrupt Practices Act," White Collar Alert (July 9, 2020). Contacts: Thomas A. Hanusik, Kelly T. Currie, Derek A. Hahn, Nimrod Haim Aviad, Arlen Pyenson
Client Alert / Newsletter
Crowell & Moring Releases Investigations Crisis Response Mobile Application (Jul.07.2020)
Firm News / Announcement
"Supreme Court Upholds SEC's Ability to Seek Disgorgement, With Limits," White Collar Alert (June 24, 2020). Contacts: Daniel L. Zelenko, Thomas A. Hanusik, Nimrod Haim Aviad, Danielle Giffuni
Client Alert / Newsletter
'Tread Lightly'- Profiting From the Pandemic Agenda (June 12, 2020)
Media Mentions
"Revisions to DOJ’s Corporate Compliance Guidance Indicate that a Dynamic, Data-Driven and Well-Resourced Compliance Program is More Important than Ever," White Collar Alert (June 8, 2020). Contacts: Jacinta Alves, Lorraine M. Campos, Carlton Greene, Derek A. Hahn, Thomas A. Hanusik, Gail D. Zirkelbach, Paul Freeman, Tiffany Wynn
Client Alert / Newsletter
"COVID-19 Enforcement: Players, Risks, and Preparation Strategies," Crowell & Moring Webinar (May 8, 2020). Presenters: James G. Flood, Thomas A. Hanusik, Mana E. Lombardo, Rebecca Monck Ricigliano, and David Robbins.
Chambers USA 2020 Ranks 53 Crowell & Moring Lawyers and 21 Practice Areas Among Best in U.S. (Apr.23.2020)
Firm News / Announcement
"SEC Issues Public Statement Regarding the Impact of COVID-19 on Earnings Guidance," Corporate Alert (April 15, 2020). Contacts: Renée Delphin-Rodriguez, Sarah Gilbert, Thomas A. Hanusik, Michael W. Lieberman, Rebecca Monck Ricigliano, Daniel L. Zelenko, William J. Bruno
Client Alert / Newsletter
"Navigating Uncharted Territory: Ensuring Your Compliance Function and Program Remain a Priority in the Current Environment," Crowell & Moring Webinar (April 14, 2020). Presenters: Evan Y. Chuck, Thomas A. Hanusik, Carlton Greene, Michelle J. Linderman, and Andrew Blasi.
"The COVID-19 Pandemic and Downstream Risk: What Companies Should Do Now to Protect Themselves Against Government Investigations and Enforcement Later," Crowell & Moring Webinar (April 7, 2020). Presenters: Thomas A. Hanusik, David B. Robbins, Paul M. Rosen, Gail D. Zirkelbach, and Tiffany Wynn.

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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, and Brussels.

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