Courtney M. Brown is a partner in the Washington, D.C. office of Gibson, Dunn & Crutcher, where she practices primarily in the areas of white collar criminal defense and corporate compliance. Ms. Brown has experience representing and advising multinational corporate clients and boards of directors in internal and government investigations on a wide range of topics, including anti-corruption, anti-money laundering, sanctions, securities, tax, and “me too” matters.

Selected investigation and enforcement matters include:

• Represented a multinational information technology company in negotiating resolutions of claims brought by the U.S. Department of Justice (“DOJ”) and Securities and Exchange Commission (“SEC”) under the U.S. Foreign Corrupt Practices Act (“FCPA”), including successful completion of a post-resolution reporting period.
• Conducted an investigation for the Board of Directors involving allegations of insider dealing against executives.
• Represented a global financial institution in a multi-agency investigation concerning the U.S. Treasuries market.
• Conducted a workplace investigation on behalf of a Special Committee of the Board of Directors.
• Represented an investment manager in an SEC investigation involving allegations of false advertising and other misconduct under securities regulations.
• Represented a defense company, obtaining declinations of criminal and civil enforcement actions by the DOJ and SEC in FCPA investigations, as well as the dismissal of an employment lawsuit brought by a former employee.
• Obtained declinations, on behalf of a Fortune 500 company, of criminal and civil enforcement actions by the DOJ and SEC in a joint FCPA investigation arising from whistleblower complaints.
• Represented banks and asset managers in investigations by the DOJ, SEC, congressional committees, and state investigators relating to subprime mortgage matters and the Madoff fraud.

Ms. Brown also counsels corporations on the effectiveness of their compliance programs and in connection with transactional due diligence, with a particular emphasis on compliance with anti-corruption laws, anti-money laundering regulations, and economic and trade sanctions administered by the U.S. Department of Treasury’s Office of Foreign Assets Control.

Ms. Brown has participated in two government-mandated FCPA compliance monitorships and conducted anti-corruption and compliance trainings for in-house counsel and employees. She also has experience advising companies on the application of the U.S. Sentencing Guidelines and, since 2014, has been a contributing author for the ABA’s treatise, “Practice Under the Federal Sentencing Guidelines.”

Ms. Brown completed a secondment at a Fortune 100 company, where she advised global legal and business teams on compliance with anti-corruption laws. Most recently, she was listed in Best Lawyers in America®  2024 for her work in Criminal Defense: White-Collar matters.

Ms. Brown received her law degree in 2008 from the University of Chicago Law School. Prior to law school, Ms. Brown worked for the Chairman of the U.S. Senate Health, Education, Labor and Pensions Committee. Ms. Brown earned her undergraduate degree from Harvard University, where she was co-captain of the NCAA Division I championship women’s crew team and an All-American selection in rowing.

Ms. Brown is a member of the bars of the District of Columbia and Virginia.