Mary Mulligan has broad and deep experience in white collar criminal defense and internal investigations: over the course of her more than 25-year career, she has handled matters involving virtually all aspects of white collar crime. Today, she represents clients in the financial services and other industries in connection with allegations of money laundering, insider trading, Foreign Corrupt Practices Act violations, criminal antitrust violations, securities fraud, tax fraud, off-label marketing, False Claim Act violations, mail and wire fraud, Internet fraud, healthcare fraud, cyberstalking, and other matters. She has also served as an integrity counsel to a hedge fund and as a monitor in the construction industry, and handles a variety of matters involving institutions of higher education and secondary schools, including advising on governance, intellectual property, and Title IX issues, conducting internal investigations, and responding to local, state, and federal inquiries.
From 1997 to 2002, Ms. Mulligan served as an Assistant United States Attorney for the Southern District of New York, directing investigations and prosecutions of fraud, public corruption, and financial crime. During this time, she led the government's largest FCPA investigation to date, which involved the alleged payment of tens of millions of dollars in bribes to the president of Kazakhstan in connection with major oil transactions in the 1990s.
Because of the nature of Ms. Mulligan’s work, many of her most successful matters have not resulted in public charges and remain confidential.
- Representation of a prominent individual in connection with federal investigations and Congressional inquiries relating to conduct during the U.S. Presidential election in 2016.
- Representation of a number of institutions in connection with internal investigations related to allegations of sexual harassment and misconduct.
- Represented numerous investment advisors, analysts, portfolio managers, and senior executives at hedge funds in various high-profile insider trading and securities fraud investigations and prosecutions brought by the U.S. Attorney for the Southern District of New York and the Securities and Exchange Commission.
- Represented Chuck Blazer, the founder of organized American soccer, relating to FIFA, the international soccer organization, in connection with investigations by the FBI, DOJ, and IRS.
- Regular representation of institutions of higher education in connection with non-public matters, internal investigations, and responding to confidential state and federal inquiries.
- Represented the former first lady of an African nation in a significant Foreign Corrupt Practices Act investigation being conducted by the U.S. Department of Justice. The case involved allegations of money laundering and violations of the Travel Act (18 U.S.C. § 1952) in connection with the award of a mining concession valued at several billion dollars.
- Representation of a former senior executive of a major medical device manufacturer in an investigation by the U.S. Department of Justice, the SEC, and the Serious Fraud Office involving allegations of FCPA violations. Ms. Mulligan and the firm are also assisting the client in connection with an ongoing investigation conducted by a European prosecuting authority into allegations of alleged fraud and money laundering.
- Represented a former senior executive of a major financial institution in connection with a publicly-reported money laundering investigation conducted by the DOJ, the U.S. Department of the Treasury, and state entities into the client’s former employer. Ms. Mulligan's client was not charged.
- Representation of witnesses in various high-profile investigations conducted by the U.S. Attorney’s Office for the Southern District of New York, including in connection with alleged public corruption, art fraud and theft, OFAC violations, and tax-related matters.
- Represented a prominent university and the former dean of its school of architecture in defense of civil litigation relating to a degree program the plaintiff allegedly helped to develop between the school and an international university.
- Ms. Mulligan and the firm conducted FCPA training for the Board of Directors of an Ivy League university.
- Represented a senior executive in connection with a confidential investigation into his alleged theft of trade secrets and intellectual property from his previous employer.
- Represented the former CEO of the Montenegro subsidiary of Magyar Telekom, a Hungarian telecommunications company, in connection with a more than four-year investigation and enforcement action by the U.S. Department of Justice and the SEC into alleged FCPA violations pertaining to the company’s operations in Macedonia and Montenegro.
Outside the Office
Ms. Mulligan is a lecturer in law at the University of Pennsylvania Law School, where, in conjunction with The Honorable Cheryl Ann Krause of the United States Court of Appeals for the Third Circuit, she teaches a seminar entitled "Crossing the Line: White Collar Crime and Securities Fraud."
Ms. Mulligan is a member of the Board of Directors of the Legal Action Center, a non-profit organization whose mission is to fight discrimination against people with histories of addiction, HIV/AIDS, or criminal records, and to advocate for sound public policies in these areas. From 2009 to 2012, she served as a commissioner of New York City's Civilian Complaint Review Board, an independent agency which handles complaints of alleged police misconduct.
New York University School of Law, J.D., cum laude (1989)
Vanderbilt University, B.A., magna cum laude (1983)
State of New York
U.S. District Courts for the Southern and Eastern Districts of New York
U.S. Courts of Appeals for the Second and Third Circuits
U.S. Supreme Court
The Honorable Henry A. Politz, U.S. Court of Appeals for the Fifth Circuit
Honors and Awards
Chambers USA, Band 3, New York, Litigation: White-Collar Crime & Government Investigations, 2019; Band 4, New York, Litigation: White-Collar Crime & Government Investigations, 2016-2018
New York Super Lawyers List, 2013-present
Order of the Coif, New York University School of Law
Libel Defense Resource Center Fellowship, New York University School of Law
American Jurisprudence Award in Administrative Law, New York University School of Law
Moot Court Advocacy Award, New York University School of Law