Meghan J. Gilligan Palermo
Meghan Gilligan Palermo’s practice focuses on civil and criminal enforcement matters and internal investigations for a wide range of health care companies, multinational corporations, private equity firms and their portfolio companies, global financial institutions, and executives. In the health care space, she has conducted investigations for a diverse array of companies in response to inquiries from federal and state authorities into alleged False Claims Act, securities fraud, and antitrust violations. She also has led investigations regarding potential FCPA and other corruption issues in various countries in Asia and Latin America, and advised clients on related regulatory and compliance program matters. Meghan’s enforcement experience includes representation of executives in domestic and foreign criminal and civil prosecutions alleging securities fraud and insider trading.
Meghan maintains an active pro bono practice with a focus on indigent criminal defense, immigrant rights, and women and children. In 2017, she served as an Assistant Federal Defender in the Southern District of New York, where she represented numerous defendants in felony cases at all stages of prosecution, including as second chair in a high-profile terrorism trial. That year, Meghan was awarded Her Justice’s Commitment to Justice Award for her representation of a client in Queens Family Court.
Prior to joining the firm, Meghan clerked for the Honorable Thomas I. Vanaskie in the Third Circuit Court of Appeals.
- Represents federally qualified health center in joint civil investigation by the U.S. Attorney’s Office for the Southern District of New York and state attorney general focused on alleged violations of the federal and state False Claims Acts.
- Represents U.S. medical device manufacturer and service provider in civil inquiry by the SEC into various accounting and disclosure matters, including issues relating to revenue recognition.
- Counsel to major pharmaceutical company in antitrust enforcement action by state attorney general focused on bundling and rebate walls.
- Advises global pharmaceutical company on regulatory and compliance issues in connection with COVID-19 vaccine trial study.
- Represents multinational scientific device manufacturer in civil investigation by SEC into alleged FCPA violations in Southeast Asia and potential revenue recognition issues.
- Represents major South American airline in government and internal investigations focused on alleged FCPA violations in connection with business activities in Latin America.
- Leads internal investigation on behalf of U.S. energy company related to FCPA and anti-money laundering risks in Latin America.
- Counsel to U.S. corporations and foreign financial institutions in assessing and enhancing anti-bribery and corruption programs and related compliance, personnel, and policy matters.
- Represented multinational financial institution and its employees in connection with civil enforcement action by the SEC concerning potential FCPA violations in the Asia-Pacific region and related inquiries by foreign regulators, including the HKMA and FINMA.*
- Counsel to former private equity firm executive in parallel criminal and civil securities fraud proceedings by the U.S. Attorney’s Office for the Southern District of New York and SEC.
- Counsel to hedge fund executives in SEC and FCA investigations concerning alleged securities law violations.
- Represented former director at global financial institution in civil insider trading probe by the SEC, negotiating to successful resolution resulting in recommendation of no enforcement action.
- Represented major broker-dealer in securities law investigations by the SEC and FINRA focused on dark pools and high-frequency trading.*
- Represented major broker-dealer in SEC investigation concerning alleged conflicts of interest among research analysts and research analyst conduct.*
Other Government & Internal Investigations
- Led investigation on behalf of private equity firm and portfolio company into potential conflicts of interest and assessment of disclosure obligations.
- Represented private equity firm in internal investigation into potential False Claims Act liability related to government contracting performed by portfolio company.
- Advised private university regarding assessment of admissions program and related potential enhancements.
- Represented major foreign financial institution in criminal investigation by the DOJ under U.S. Tax Program for Swiss Banks and related inquiries by foreign regulators.*
Litigation and Appellate
- Represented multinational financial institution in commercial litigations in New York State related to asset-backed securities through successful appeal and/or negotiated resolution.*
- Represents coalition of nonprofit and private plaintiffs in litigation challenging the federal government’s discovery policies in immigration proceedings.
- Advises nonprofit and private clients regarding COVID-19 relief program eligibility and related issues, including the Paycheck Protection Program.
- Counsel to juveniles in proceedings for Special Immigrant Juvenile Status.
- Represented client in appeal of second degree murder conviction and clemency petition.*
- Represented client in petition to enforce child support order in Queens Family Court.*
- Advised national nonprofit regarding legal challenges related to firearms legislation.*
- Co-author, “Individuals in Cross-Border Investigations or Proceedings: The US Perspective,” The Practitioner’s Guide to Global Investigations (2021)
- “It’s Not Popular But It Sure Is Right: The (In)Admissibility of Statements Made During the Course of Sex Offender Treatment Programs,” Syracuse Law Review (2012)
- JD, summa cum laude, Syracuse University College of Law, 2012; Associate Notes Editor, Syracuse Law Review; Justinian Honorary Law Society; Order of the Coif; Order of Barristers; Moot Court Honor Society
- BA (English, Political Science), magna cum laude, University of Rochester, 2009; Phi Beta Kappa; Take 5 Scholar
Admissions / Qualifications
- New York, 2013
- U.S. Court of Appeals for the Third Circuit, 2013
- U.S. District Court for the Eastern District of New York, 2013
- U.S. District Court for the Southern District of New York, 2013
- Her Justice Commitment to Justice Award (2017)
- Empire State Counsel Honoree (2013, 2015)