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Claudius O. Sokenu

Partner
Claudius Sokenu, a former senior counsel with the United States Securities and Exchange Commission, Division of Enforcement, is a partner in Shearman & Sterling’s Litigation Department.  Mr. Sokenu focuses his practice on representing public and privately held companies, financial institutions, accounting firms, and their directors, officers, and employees in complex civil litigation, securities and other regulatory enforcement, securities class action litigation, white-collar criminal defense, derivative actions, congressional investigations, corporate and government internal investigations, and corporate crisis management.  Mr. Sokenu has extensive experience in handling delicate, high-profile matters that require concurrent representation in the civil, criminal, and political spheres.
Mr. Sokenu has represented public and privately held companies and individuals domestically and internationally before, among others, the Department of Justice, United States Attorneys’ offices, the SEC, Commodity Futures Trading Commission, and the New York and Massachusetts Attorneys General, the New York County District Attorney, the New York State Department of Financial Services, the United Kingdom’s Serious Fraud Office, Munich Prosecutor’s Office, Brazil’s Federal Public Prosecutor’s Office, and other federal, state, and local law enforcement and regulatory authorities in the United States and abroad.

Before entering private practice, Mr. Sokenu served in the Washington, DC office of the SEC in the Division of Enforcement, on the Honors Program, first as a Staff Attorney and later as Senior Counsel, where he was responsible for handling a broad range of the Commission’s domestic and international enforcement matters, including investigations involving accounting fraud, insider trading, initial public offerings, illicit payments under the FCPA, investment companies and investment advisers, market manipulation, and broker-dealer misconduct.  He was also a member of the Enforcement Division’s FCPA Working Group, which is now known as the FCPA Unit.  As a member of the Enforcement Division, he handled a number of high-profile enforcement matters, including the Commission’s first-ever joint FCPA enforcement action with the Justice Department against KPMG and Baker Hughes, Inc.; an FCPA enforcement action against a chief financial officer of a publicly traded oil services company; an FCPA enforcement action against a former controller of an oilfield services company; and the SEC’s enforcement action against Goldman Sachs & Co. for violations of the federal securities laws in connection with the initial public offerings of PetroChina Company Limited, China Telecom Hong Kong Limited, Chinadotcom Corp., and Giga Media Limited for which Goldman Sachs served as underwriter.

Mr. Sokenu has been consistently recognized by both Chambers Global and Chambers USA as an FCPA Expert and for his investigative, regulatory, and securities enforcement practice.  In 2016 and 2015, he was named a Litigation Star by Benchmark Litigation.  In 2013, Mr. Sokenu was ranked in the Latin Lawyer 250 for White-Collar Crime and Compliance.  Additionally, in January 2011, Mr. Sokenu was named one of seven “Best FCPA Lawyers Outside the Beltway” by Main Justice, an independent news organization that covers the Justice Department.  In February 2011, Mr. Sokenu was awarded the 2011 Outstanding Outside Counsel award by the National Bar Association, Commercial Law Section.  He was named to Diversity & The Bar’s “Leading Law Firm Rainmakers” list in December 2010.  In February 2007, Mr. Sokenu was named to Securities Law360’s “10 Under 40,” a list of 10 lawyers under the age of 40 who have demonstrated an outstanding breadth of knowledge and experience in the securities enforcement and litigation field.  In 2005, the City Bar Association of New York appointed Mr. Sokenu to serve on the Task Force on the Role of Attorneys in Corporate Governance.  In 2003, the Minority Corporate Counsel Association honored Mr. Sokenu as an Outstanding Outside Corporate Counsel.  In 2001, the Association of the Bar of the City of New York honored Mr. Sokenu for outstanding pro bono work in connection with a petition for a writ of certiorari to the Supreme Court of the United States.

Mr. Sokenu is an Adjunct Professor of Law at Georgetown University Law Center in Washington, DC, where he teaches advanced level securities enforcement and litigation courses. Mr. Sokenu has lectured and published extensively on securities enforcement and litigation matters and has been consulted extensively by the financial press on a variety of securities law issues.

Selected Experience

  • Represented AXA in a Justice Department corruption, asset forfeiture and money-laundering action against Teodorín Nguema Obiang Mangue, the Minister of Agriculture and Forestry and Vice-President of the ruling party of Equatorial Guinea. Teodorín is also the eldest son of President Teodoro Obiang Nguema Mbasogo of Equatorial Guinea, U.S. v. One Gulfstream G-V Jet Aircraft, No. CV 11-1874 CRC.
  • Representing GlaxoSmithKline in connection with a global anti-corruption investigation by the Department of Justice, SEC, and the UK’s Serious Fraud Office.
  • In re Herald, Primeo and Thema Securities Litigation, No. 09-289, 2011 WL 5928952 (S.D.N.Y. Nov. 29, 2011), aff’d, No. 12-162-cv (2d Cir. Sept. 16, 2013): Lead counsel for Ernst & Young Global Limited in a number of securities class actions in the Southern District of New York stemming from the Madoff Ponzi scheme scandal.

Selected Professional Articles

  • Securities Enforcement 2015 Mid-Year Review, July 2015
  • "SEC says Confidentiality Agreements may Impede Whistleblower", April 2, 2015
  • "How a Skilled Board should Manage an Internal Investigation", Directors & Boards, March 24, 2015
  • Securities Enforcement 2014 Year-End Review, January 2015
  • "Broken Windows: SEC Enforcement Reminds Officers, Directors, and Five Percent Shareholders to Comply with Reporting Requirements", September 2014
  • Securities Enforcement 2014 Mid-Year Review, July 2014
  • "So You Want to See Messi, Neymar, Ronaldo, and Xavi: Brazil Issues Directive Barring Government Officials From Receiving World Cup Tickets", June 2, 2014
  • SEC Enforcement 2013 Year-End Review, January 2014 
  • Co-authored “Personal Jurisdiction over Foreign Nationals in Foreign Bribery Cases Curtailed,” Legal Backgrounder,  Vol. 28, No. 3, May 3, 2013
  • Co-authored “FCPA Update: Key Enforcement and Investigative Developments,”Financial Fraud Law Report, November/December 2012
  • Co-authored “Industry-Wide Investigations Under the Foreign Corrupt Practices Act”, Financial Fraud Law Report, November/December 2012
  • “10 Lessons From 2011 Enforcement Activity,”White Collar Law360, February 15, 2012
  • “Corruption Is Profitable for U.S. Government: FCPA Enforcement Crackdown Continues,” The Legal Pulse, 28 Mar. (2011)
  • “2010 FCPA Enforcement Year-End Review,”The Bureau of National Affairs, Inc., 21 Mar. (2011)
  • “Bribery Act is not perfect but brings UK into line with OECD,” The Guardian, February 4, 2011
  • “Inside the Minds: Foreign Corrupt Practices Act Compliance Issues,” Aspatore Books, Publishers of C-Level Business Intelligence, July 2010
  • “Complying With The FCPA And Doing Business In China: A Perilous Balancing Act,” Financial Fraud Law Report, May 2010
  • “Another Record Year Brings To An End A Decade That Saw The Explosion Of FCPA Prosecution-PART II,” Financial Fraud Law Report, May 2010
  • “Another Record Year Brings To An End A Decade That Saw The Explosion Of FCPA Prosecution-PART I,” Financial Fraud Law Report, April 2010
  • Co-authored “Cross-Border Investigations,” GC New York Guide: New York Law Journal, October 26, 2009
  • Co-authored “Alarming lessons from Siemens,” International Financial Law Review, July/August 2009
  • “DOJ Again Clarifies FCPA Due Diligence Expected in Business Combinations,” Securities Regulation & Law Report, Vol. 40, No. 34, August 25, 2008
  • “Sparing No Travel Expenses,” The Australian Corporate Lawyer, Vol. 18, No. 1, March 2008
  • “Clarifying Travel and Entertainment Under the FCPA,” New York Law Journal, Vol. 239, No. 49, March 13, 2008
  • “To Host Or Not To Host: Approving Travel And Entertainment Under The Foreign Corrupt Practices Act,” Securities Regulation & Law Report, Vol. 40, No. 10, March 10, 2008
  • Co-authored “Corruption Without Frontiers,” The Australian Corporate Lawyer, Vol. 17, No. 4, December 2007
  • “Lessons From Record Penalty Under Federal Anti-Corruption Law,” Washington Legal Foundation, Legal Opinion Letter, Vol. 17, No. 15, June 22, 2007
  • Co-authored “Pitfalls of Attempts To Cooperate with Enforcement Agencies,” Review Of Securities & Commodities Regulation, Vol. 40, No. 11, June 6, 2007
  • “FCPA: Baker Hughes Settles Bribery Charges,” New York Law Journal, August 2, 2007
  • Co-authored “The Current Enforcement Environment and the Corporate Response,” Review Of Securities & Commodities Regulation, Vol. 40, No. 9, May 2, 2007
  • Co-authored “Will McNulty's Revisions Pacify Critics of the Thompson Memorandum?,” Andrews Securities Litigation & Regulation Report, Vol. 12, No. 22, March 7, 2007
  • Co-authored “Foreign Corrupt Practices Act Enforcement After US v. Kay,” Washington Legal Foundation, October 2006
  • “Much Ado About Nothing: SEC Announces Principles for Imposing Monetary Penalties on Issuers,” Andrews Securities Litigation & Regulation Report, Vol. 11, No. 20, February 8, 2006; Andrews Corporate Officers & Directors Liability Litigation Report, Vol. 17, February 20, 2006
  • Co-authored “Scope of Foreign Corrupt Practices Act's Bribery Provision Set,” New York Law Journal, June 29, 2005
  • “No Longer ‘Kinder and Gentler’: SEC Raises Stakes in Settled Enforcement Actions,” Washington Legal Foundation, Legal Backgrounder, Vol. 18, No. 51, December 5, 2003
  • “SEC Expands Foreign Corruption Law Beyond Congressional Intent,” Andrews Securities Litigation & Regulation Report, Vol. 8, No. 5, August 14, 2002; Derivatives Litigation Report, Vol. 8, No. 19, August 14, 2002; Washington Legal Foundation, Legal Backgrounder, Vol 17,  No. 28, July 26, 2002
  • “Web Portals Rouse SEC: Who is a Trader, After All?” The National Law Journal, March 11, 2002
  • “Web Portals Caught in the Web of Broker-Dealer Regulation,” New York Business Law Journal, Spring 2002; eSecurities, Vol. 4 No. 7, at 3, March 2002
  • Co-authored “SEC Self-Policing Policy Presents Benefits and Pitfalls,” White Collar Crime Report, Vol. 16 No. 7, June 24, 2002; Andrews Securities Litigation & Regulation Report, Vol. 7, No. 17, February 27, 2002
  • “Avoiding Civil Monetary Penalties in SEC Enforcement Actions,” New York Business Law Journal, Spring 2002; New Jersey Law Journal, December 24, 2001

Selected Presentations

  • Panelist, 2016 SIFMA Compliance and Legal Society Annual Seminar, “Ethics for Lawyers Serving Financial Services,” Orlando, FL, March 2016
  • Program Chair, “Recent Trends in Foreign Corrupt Practices Act Litigation, Enforcement & Compliance,” New York City Bar, New York, NY, March 2016
  • Panelist, “The Foreign Corrupt Practices Act and International Anti-Corruption Developments,” Practising Law Institute, New York, NY, May 2016
  • Panelist, 2015 SIFMA Compliance and Legal Society Annual Seminar, “Diversity and Inclusion in the Securities Industry,” Phoenix, AZ, March 2015
  • Panelist, “Handling a Securities Case:  From Investigation to Trial and Everything in Between,” Practising Law Institute, New York, NY, April 2015
  • Panelist, “The Foreign Corrupt Practices Act and International Anti-Corruption Developments,” Practising Law Institute, New York, NY, May 2015
  • Program Chair, “Recent Trends in Foreign Corrupt Practices Act Litigation, Enforcement & Compliance,” New York City Bar, New York, NY, March 2015, 2014, 2013
  • Panelist, “The Foreign Corrupt Practices Act and International Anti-Corruption Developments,” Practising Law Institute, New York, NY, May 2014
  • Panelist, “Handling a Securities Case:  From Investigation to Trial and Everything in Between,” Practising Law Institute, New York, NY, April 2014
  • Panelist, “The Foreign Corrupt Practices Act and International Anti-Corruption Developments,” Practising Law Institute, New York, NY, May 2013
  • Program Chair, “Recent Trends in Foreign Corrupt Practices Act Litigation, Enforcement & Compliance,” New York City Bar, New York, NY, March 2012
  • Program Chair, White Collar Crime 2009:  Prosecutors & Regulators Speak, Practising Law Institute, New York, NY, October 5, 2012
  • Panelist, “Global Enforcement Trends:  Assessing and Preparing for Emerging US and UK Civil and Criminal Risks for Financial Institutions,” New York, NY, July 12, 2011
  • Speaker, “SEC, Whistleblowing, and the Foreign Corrupt Practices Act,” Legally Brief, Washington Legal Foundation, Washington, DC, October 18, 2010
  • Speaker, “Recent Developments in White Collar Litigation: The Foreign Corrupt Practices Act and Other White Collar Issues,” Minority Attorney Summit, Washington, DC, May 7, 2010
  • Panelist, “23rd National Conference on Foreign Corrupt Practices Act,” American Conference Institute, New York, NY, March 23-24, 2010
  • Panelist, “Conducting a Global Corporate Investigation,” Georgetown University Law Center, Washington, DC, November 23, 2009
  • Panelist, “Gifts & Hospitality in High-Risk Markets:  How to Balance Local Customs and the Letter of the Law,” 22nd National Forum on Foreign Corrupt Practices Act, American Conference Institute, Washington, DC, November 18, 2009
  • Program Chair, “Complying With FCPA in a Heightened Enforcement Environment:  What Advice You Need to Give Your Clients & When,” The Association of the Bar of the City of New York, New York, NY, October 28, 2009
  • Panelist, “Enforcement Developments,” Advanced Securities Law Workshop, Practising Law Institute, New York, NY, October 9, 2009
  • Program Chair, “Approach of the Serious Fraud Office to Dealing With Overseas Corruption,” White Collar Crime 2009:  Prosecutors & Regulators Speak, Practising Law Institute, New York, NY, October 5, 2009
  • Panelist, “High Tech-High Risk 2009: Foreign Corrupt Practices Act Implications for Technology Companies,” Practising Law Institute, Sun Microsystems, Silicon Valley, CA, September 17, 2009
  • Panelist, “Securities Law and Regulatory Compliance 2009:  Current Perspectives,” National Bar Association, 84th Annual Convention, San Diego, CA, August 5, 2009
  • Panelist, “The Foreign Corrupt Practices Act 2009:  Coping with Heightened Enforcement Risks,” Program Chair, Practising Law Institute, San Francisco, CA, June 26, 2009
  • Panelist, “The Foreign Corrupt Practices Act 2009:  Coping with Heightened Enforcement Risks,” Program Chair, Practising Law Institute, University of Chicago, Gleacher Center, Chicago, IL, May 29, 2009
  • Panelist, “Ethisphere Symposium:  Pre-acquisition Due Diligence,” Ethisphere Institute, May 1, 2009
  • Panelist, “The Foreign Corrupt Practices Act 2009:  Coping with Heightened Enforcement Risks,” Program Chair, Practising Law Institute, New York, NY, April 29, 2009
  • “Overcoming FCPA Compliance Challenges in West Africa,” 21st National Forum on Foreign Corrupt Practices Act, American Conference Institute, Washington, DC, November 18, 2008
  • Program Chair, “White Collar Crime 2008:  Prosecutors and Regulators Speak,” Practising Law Institute, New York, NY, September 2008
  • Program Chair, “FCPA:  Complying & Implementing Risk Management Strategies,” City Bar Association of New York, New York, NY, November 2007, September 2008
  • Panelist, “Advanced Securities Law Workshop,” Practicing Law Institute, San Diego, CA, August 2008, August 2007
  • Panelist, “Foreign Corrupt Practices Act in India,” Strafford Publications, May 2008
  • Panelist, “3rd Annual Investment Management Regulatory University,” Chicago, IL, May 2008, London 2007
  • Panelist, “The Foreign Corrupt Practices Act:  Coping with Heightened Enforcement Risks,” Practicing Law Institute, New York, NY, San Francisco. CA, and Chicago, IL, 2008
  • Panelist, “The Foreign Corrupt Practices Act:  Coping with Heightened Enforcement Risks,” Practicing Law Institute, San Francisco, CA, September 2007; New York, NY, February 2007,
  • Panelist, “SEC Enforcement Trends:  Is Bad News Better If You Get It Sooner?,” Minority Corporate Counsel Association, Annual CLE Expo, Chicago, IL, March 2007
  • Panelist, “View From the Sources,” New York City Bar, New York, NY, January 2007
  • Panelist, “Last Chance CLE:  Important Legal Developments in 2006,” Practicing Law Institute, New York, NY, December 2006
  • Panelist, “Securities Regulators:  View From The Sources,” New York City Bar, New York, NY, June 2006
  • Panelist, “Lawyers as Gatekeepers:  Conducting Internal Investigations,” MetLife Lecture Series, New York, NY, January 2006
  • Panelist, “Institute For The Young Business Lawyer,” Panel on Federal Regulation of Securities, American Bar Association, Nashville, TN, March 2005
  • Panelist, “Conducting Internal Corporate Investigations,” TIAA-CREF Lecture Series, New York, NY, February 2005
  • Panelist, “Current Issues in Internal Corporate Investigations,” New York City Bar, New York, NY, January 2005
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Education

  • Georgetown University Law Center, LL.M., Securities and Financial Regulations
  • London School of Economics & King's College London, LL.M., Corporate & Commercial Law
  • London South Bank University, LL.B., Upper Class Honors

Admissions/Qualifications

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