Genieva DePass is a white-collar and investigations lawyer whose practice centers on government-initiated and internal investigations, compliance counseling, and crisis response for multinational companies. Genieva has served as lead associate on high-stakes matters across the health care, life sciences, education, and commodities sectors in responding to inquiries from the U.S. Department of Justice, Securities and Exchange Commission, Federal Trade Commission, congressional committees, and state regulators. Genieva conducts cross-border internal investigations involving the False Claims Act, the Anti-Kickback Statute, the Foreign Corrupt Practices Act, and related federal and state laws, and advises clients on remediation and regulator-facing strategy. Genieva brings practical, in‑house perspective from a full‑time secondment in a global pharmaceutical company’s anti‑bribery/anti‑corruption center of excellence, and advises clients on crisis response to reputational risks, including sensitive workplace and equity and inclusion issues.
In recognition of her leadership, mentorship, and commitment to the firm’s values, Genieva received Ropes & Gray’s Torch Award, honoring those who carry the firm’s tradition of excellence forward. In 2023, Genieva was also selected as a Leadership Council on Legal Diversity (LCLD) Pathfinder, a national program designed to cultivate future leaders in the legal profession.
Experience
Government & Internal Investigations
- Representing a multinational medical device and health care company in their response to a Civil Investigative Demand issued by the DOJ concerning two cardiac devices used together.
- Represented board members of a health and wellness company in settlement of FTC Bureau of Consumer Protection investigation and lawsuit.
- Represented a Special Committee of the Board of Directors of a health care company related to an investigation into a subsidiary and its potential CEO misconduct.
- Lead associate representing various public and private academic institutions and universities in conducting internal investigations and responding to government inquiries related to foreign influence and alleged NASA Wolf Amendment violations.
- Represented a senior living facility facing a Congressional inquiry related to COVID-19 practices.
- Lead associate in comprehensive policies, practices, organizational governance review for a high-profile association, which informed its efforts to implement a comprehensive multi-year diversity, equity, and inclusion strategy.
- Assisted in the independent investigation commission by the U.S. Olympic and Paralympic Committee into Larry Nassar’s abuse of elite athletes, which resulted in a detailed public report.
- Assisted in the defense of a special purpose acquisition company against an investigation brought by the U.S. Securities and Exchange Commission, ultimately securing a complete walk away.
- Represented global pharmaceutical and medical device companies in DOJ and internal investigations involving alleged violations of False Claims Act and Anti-Kickback Statute relating to promotion and sales of company products.
- Represented a global pharmaceutical company in defense against allegations of violations of the False Claims Act and the Food, Drug, & Cosmetic Act.
Compliance Counseling / Compliance Monitorships
- Representing a multinational networking and telecommunications company with a comprehensive compliance risk assessment of its significant operations in Latin America in light of the renewed focus and changing enforcement priorities of the U.S. authorities in the region.
- Lead associate who supported the FCPA Independent Compliance Monitor, appointed by the U.S. Department of Justice, in monitoring and assessing the anti-bribery and anti-corruption compliance controls at Glencore, a multinational commodity trading and mining company.
- Lead associate in the independent review of a biopharmaceutical company’s compliance monitoring program targeting policy violations creating potential Anti-Kickback Statute risk.
- Assisted independent compliance monitor in assessing the sufficiency of anti-bribery compliance controls of an aircraft manufacturer pursuant to a Deferred Prosecution Agreement with the DOJ and SEC.
- Advised global pharmaceutical manufacturer on risk of anti-bribery and corruption risk in Covid-19 partnerships, collaborations, and commercial transactions.
Pro Bono
- Active participant in the D.C. Landlord Tenant Resource Center, providing pro bono assistance to unrepresented tenants and landlords in housing matters.
- Represented multiple domestic violence victims seeking Civil Protection Orders.
- Part of litigation team that represented criminal defendant in a wrongful conviction matter, securing an Alford plea, with a sentence of time served, following grant of petition for writ of actual innocence based on DNA evidence undermining homicide convictions and life sentences from trials in 1981 and 1983. Team was awarded firm-wide 2018 Pro Bono Team Award.