Practice & Background

Aaron G. Murphy focuses on Foreign Corrupt Practices Act (FCPA) compliance counseling and investigations for large and mid-sized companies, including responding to and resolving Department of Justice and Securities and Exchange Commission (SEC) inquiries. Mr. Murphy’s clients include Fortune 100 companies, individual officers and directors, special board committees, and smaller companies and individuals associated with those companies. He has conducted corruption investigations in more than 25 countries, including numerous multijurisdictional FCPA probes.  Mr. Murphy has particularly deep experience in Asia, having conducted more than a dozen investigations in China alone.  He is the author of the highly regarded Foreign Corrupt Practices Act: A Practical Resource for Managers and Executives.

Mr. Murphy’s non-FCPA work covers a broad range of areas. During his career, he has handled domestic bribery and corruption matters, investigations conducted by the Department of the Treasury’s Office of Foreign Asset Control, money laundering and federal criminal gambling offenses, qui tam litigation, SEC enforcement actions, criminal tax and Medicare fraud and congressional investigations and public corruption scandals.

Mr. Murphy’s recent non-corruption work includes serving as the lead investigator of stock option backdating allegations at three different publicly traded companies; obtaining a dismissal, on behalf of one of the largest participants in the secondary mortgage market, of a massive False Claims Act case that alleged insurance fraud on the Department of Housing and Urban Development; and successfully defending against a 23-count criminal action alleging violations of various environmental and zoning laws. He has also served as deputy general counsel to the Citizen’s Commission on Jail Violence, established by the Los Angeles County Board of Supervisors to investigate allegations of widespread prisoner abuse within the Los Angeles County jails, and obtained a 25-year prison term reduction on behalf of a 15-year-old client convicted of second-degree murder.

Earlier in his career, Mr. Murphy served as a judicial clerk to the Honorable Sidney R. Thomas of the United States Court of Appeals for the Ninth Circuit from 1999-2000.

Representative Matters

Mr. Murphy’s representative matters include acting as or on behalf of:

  • investigative team leader in several multi-jurisdictional FCPA investigations in Asia, Africa, Europe and Central Asia, including hundreds of in-country witness interviews on five continents
  • lead role in investigating stock option backdating allegations at three different publicly traded companies
  • lead role in investigating allegation of fraud committed on the Department of Housing and Urban Development under the False Claims Act; achieved dismissal of the case reported at United States ex rel. Cericola v. Fannie Mae, 529 F. Supp. 2d 1139 (C.D. Cal. 2007).
  • multiple healthcare fraud investigations involving allegations of false claims for Medicare reimbursements
  • defense of an enforcement action by the Securities and Exchange Commission alleging channel stuffing and other revenue recognition issues
  • defense of a 23 count criminal action against a recycling company for violations of various environmental and zoning laws.
  • numerous confidential internal investigations into criminal allegations by federal and state authorities.

In addition, Mr. Murphy has substantial experience in appellate matters.

Awards and Accolades

  • Received the ACLU of Southern California’s Community Service Pro Bono Award, May 2013
  • Received Certificate of Appreciation from the County of Los Angeles in recognition of work as the Deputy General Counsel to the Citizen’s Commission on Jail Violence, November 2012
  • Received the ACLU of Southern California’s Immigration Rights Advocacy Award, June 2012
  • Received the California State Bar’s Wiley A. Manuel Award for Pro Bono Legal Services, June 2007
  • Public Justice Trial Lawyer of the Year Finalist for 2007

Speaking Engagements

  • “Joint Ventures – A Complete Guide to Navigating the Challenges of Local Content Rules and Requirements,” American Conference Institute, FCPA Boot Camp, Houston, January 2014
  • “What You Need to Know About the FCPA,” USC Master of Accountancy Program, March 2013
  • “The Nuts and Bolts of Compliance: Defining the Limits of Gift Giving, Hosting and Hospitality,” The Canadian Institute’s Anti-Corruption Conference, Toronto, February 2013
  • “What to Do When Your Organization is the Subject of an Investigation,” The Canadian Institute’s Anti-Corruption Conference, Toronto, January 2013
  • “Guidance on the Guidance,” Latham & Watkins Webinar, December 2012
  • “What You Need to Know About the FCPA,” USC Master of Accountancy Program, October 2012
  • “What You Need to Know About the FCPA,” Utah State Bar Convention, Sun Valley, July 2012
  • “Stepped Up Vigilance: The Surge in Anti-Corruption Enforcement,” Responsible Sourcing Summit, Los Angeles, February 2012
  • “To Disclose or Not to Disclose,” The Canadian Institute’s Anti-Corruption Conference, Toronto, January 2012