Courtney D. Trombly

• Serving as counsel to the monitor, Frances McLeod of Forensic Risk Alliance ("FRA"), and works arm-in-arm with FRA to lead the combined DOJ monitorship team for Balfour Beatty Communities ("BBC"). BBC pled guilty to major fraud against the United States in December 2021, and DOJ imposed an independent compliance monitor as part of that plea agreement. The monitorship team focuses on evaluating and testing the BBC compliance program and fraud controls in key categories such as government contracts, self-dealing, corruption, conflicts of interest, and government disclosure and reporting requirements.
• Represented Albemarle Corporation, an international chemical company, in connection with government investigations, an internal investigation, and extensive compliance counseling involving multiple jurisdictions in Southeast Asia, China, the Middle East, South American, and Africa. The company reached settlements with the DOJ and SEC in 2023, and the DPP declined prosecution. Citing Albemarle's extraordinary efforts to timely and effectively remediate its compliance program and internal controls, the DOJ did not impose a monitorship. Since the resolution, DOJ Fraud Section officials have repeatedly and publicly cited Albemarle's compliance design and implementation efforts and responses to the misconduct as exemplary.
• Representing U.S.-based multinational medical device company in investigation of potential anti-corruption and other legal and policy violations in the Middle East and Southeast Asia. A key part of the engagement includes compliance remediation, including conducting root cause analyses and assessing the effectiveness of the global anti-corruption compliance program.
• Represented a leading U.S. manufacturer in internal investigation and response to a subpoena issued by BIS related to compliance with complex export control regulations involving China, including the de minimis and foreign direct product rules.
• Represented multinational Fortune 500 retail client in global anti-corruption risk and compliance program assessment. The client has affiliates in over 50 countries and indirect sales into more than 100 geographies, and the project is focused on identifying and "mapping" risk, assessing the effectiveness of corresponding mitigating controls, and advising on the design and implementation of enhancements to the existing compliance program according to U.S. DOJ and other regulatory guidance regarding the same.
• Represented multinational Fortune 50 company in multiple False Claim Act investigations involving the DOJ, multiple state attorneys general, the General Services Administration ("GSA") and other government agencies.
• Represented one of the largest global medical device companies in multinational FCPA internal investigation in five European countries, China, Brazil, and elsewhere, advised on the design and implementation of an enhanced global anti-corruption compliance program; and represented company in response to parallel investigations by the DOJ and SEC, resulting in prosecution declinations from both agencies.
• Represented a global oilfield services provider in its July 2017 FCPA resolution with the SEC (DOJ declined prosecution). Courtney and a team from K&S led the effort to investigate potential misconduct in Angola and other Middle Eastern countries, and advised on ongoing compliance remediation and controls enhancements throughout the court of the matter, including interfacing and collaborating with the SEC-appointed independent compliance consultant.
• Advises clients on a wide array of international compliance matters, with specific knowledge and focus on the design and implementation of corporate compliance programs tailored specifically to an organization's risk, industry, geographic, and operational profile.
• Representing pool of individual employees of a foreign company in Asia under investigation by the DOJ and other federal agencies for fraud, drug trafficking, and other violations of federal law the government views as derivative of the company's failure to implement an effective compliance program.

Courtney Trombly focuses on white-collar criminal defense including anti-corruption investigations and compliance counseling, False Claims Act investigations and litigation, and cross-border investigations and disputes. As a partner in our Special Matters and Investigations practice, Courtney represents clients worldwide in a variety of high-stakes matters.

As a partner in our Special Matters and Investigations practice, Courtney represents clients worldwide in a variety of high-stakes matters.

Courtney focuses on white-collar criminal defense including issues involving anti-corruption, fraud, False Claims Act, and cross-border investigations and disputes.  Her practice also focuses on compliance program evaluation and counseling, including expertise in risk assessment, root cause analysis, and enhancement of compliance programs based on “lessons learned” through investigations and compliance monitoring.  Courtney also has deep expertise and experience with independent compliance monitorships and oversight, having served on both sides of such efforts.

Prior to joining our firm, Courtney served for more than three years as an Assistant U.S. Attorney in the Middle District of Tennessee, where she was part of the Criminal Division's White Collar and Corporate Fraud Unit. In that role, she was lead counsel on dozens of investigations into white-collar crime, including public corruption, money laundering and securities, bank, ERISA, mail, wire, healthcare and bankruptcy frauds, and also prosecuted counterfeiting, computer, narcotics, child exploitation and environmental crimes. On several occasions, she acted as lead counsel on briefs and oral arguments before the Courts of Appeals for the Second and Sixth Circuits.

Before that, Courtney was a Captain in the United States Marine Corps. As a defense counsel at Camp Lejeune, she represented hundreds of Marines and sailors in criminal courts-martial and administrative proceedings. She also served as lead counsel in bench and jury trials, and obtained numerous outright acquittals for her clients. For her service, she was awarded the 2005 USMC Defense Counsel of the Year Award, Eastern Region, and also received the Navy Achievement Medal.