Meghan Gilligan Palermo’s practice focuses on civil and criminal enforcement matters and internal investigations for a wide range of investment advisors, global financial institutions, health care companies, multinational corporations, and their executives. Meghan regularly counsels investment advisors and publicly traded companies in internal investigations and actions by the Securities and Exchange Commission and other regulators concerning disclosures, conflicts of interest, insider trading, and fraud. 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.
Experience
Securities Enforcement
- Represents private equity firm in insider trading inquiry by the DOJ and SEC.
- Represents private equity firm in response to SEC inquiry into cryptocurrency investments.
- Led internal investigation by sponsor into potential FCPA and accounting fraud violations at China-based portfolio companies, including advising on disclosure obligations and risk mitigation.
- 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.
- Represented 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.
- 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.*
- Represented former advisor to private equity firm in criminal and insider trading probe by the DOJ and SEC.
- 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.
- 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.
Anti-Corruption and Fraud Enforcement
- Represents major global financial institution in inquiry by DOJ concerning potential violations of anti-money laundering laws.
- Represented 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.
- Represented multinational scientific device manufacturer in civil investigation by SEC into alleged FCPA violations in Southeast Asia and potential revenue recognition issues.
- Represented major South American airline in government and internal investigations focused on alleged FCPA violations in connection with business activities in Latin America.
- Led internal investigation on behalf of U.S. energy company related to FCPA and anti-money laundering risks in Latin America.
- 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.*
Other Government & Internal Investigations
- Counsel to major pharmaceutical company in antitrust enforcement action by Federal Trade Commission and state attorney general focused on bundling and rebate walls.
- Advised global pharmaceutical company on regulatory and compliance issues in connection with COVID-19 vaccine trial study.
- 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
- Represents witness in civil litigation alleging securities fraud in connection with the offering of exchange traded notes.
- Represented not-for-profit organization in successfully achieving mediated resolution of years-long dispute with former corporate parent, including resolution of civil litigation with potential for multi-million dollar damages.
- Represented multinational financial institution in commercial litigations in New York State related to asset-backed securities through successful appeal and/or negotiated resolution.*
Pro Bono
- 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.*
*Experience prior to joining Ropes & Gray