Jerome Tomas

Practice Areas

Jerome Tomas is co-chair of the North America Government Enforcement practice group. He has been recognized by Chambers for White Collar Crime & Government Investigations. He represents multinational companies faced with government investigations and conducts internal investigations to assess and remediate legal and compliance concerns in domestic and global operations. Jerome leads teams of lawyers to address government law enforcement perspectives and where necessary, meet and refute government legal theories of corporate and individual liability head-on, while also being pragmatic and business-oriented for management and boards to compete internationally.

Jerome has extensive experience representing clients in government litigation and enforcement investigations before the SEC, DOJ, various United States Attorneys Offices and the Commodities Futures Trading Commission . On multiple occasions, he has obtained complete declinations of enforcement action from federal and state agencies. Jerome has handled investigations and prosecutions relating to the FCPA, securities fraud and manipulation, SEC reporting-related misconduct, financial statement disclosures, auditor independence, insider trading, commodities manipulation, money laundering, the Food Drug and Cosmetic Act, including the Responsible Corporate Officer Doctrine, the US wire and mail fraud statutes and OFAC-related matters, among others.

With his experience as a former member of the SEC Division of Enforcement’s Cyberforce, the agency’s internet and cyber fraud unit, Jerome regularly advises companies involved in data security breaches and incident response, including navigating through initial reports of potential compromise, to investigating, coordinating, and reporting to federal and state authorities, consumer notification and ultimately remediating.

Jerome also regularly advises multinational companies on risk mitigation and compliance in the context of international mergers and acquisitions, other business combinations, and general corporate transactions. He has advised on anticorruption and trade compliance in transport, telecommunications, mining, oil and resource extraction, chemical, defense, pharmaceutical, health care, agriculture, technology, hotel, travel, hospitality, consumer products and manufacturing industries. He also advises on compliance with US and international anti-money laundering laws and the US Bank Secrecy Act.

Professional Memberships

• American Bar Association, ABA Securities Enforcement Committee - Co-chair

• Association of SEC Alumni (ASECA) - Member

Publications

• Co-author, “So You Bought a Company . . . Now What? Post-Acquisition Integration and Acquirers' Liability for Targets' Improper Payments”

Presented at the American Bar Association’s 38th National Institute on White Collar Crime (March 1-3, 2023)

• Co-author, “The Promise and Perils of International Joint Ventures:

Potential Liability for Minority Joint Venture Partners Under the U.S. Foreign Corrupt Practices Act”

Presented at the American Bar Association’s 37th National Institute on White Collar Crime (March 2-4, 2022

• Co-author, "How SPACs Can Avoid Failed China Reverse Mergers 2.0," Law360, 27 April 2021

• Co-author, "How to Avoid Public Company Disclosure Scrutiny After Covid-19," Bloomberg Law, 4 June 2020

• Co-author, "How to Fight 'Relief Defendant' Status in SEC Actions," Law360, 14 May 2020

Expert in these Jurisdictions

USA

Languages Spoken

English

Spanish

Education