How does West Coast white collar defense practice differ from East Coast white collar practice?
Well, as Michael Li-Ming Wong points out, for better or for worse, the F in FCPA stands for “foreign.”
That would be — Foreign Corrupt Practices Act.
In some ways, it doesn’t matter where you sit.
Any FCPA practice is both a national and international practice.
Wong, a former federal prosecutor, is now a partner at Gibson Dunn in San Francisco.
More than half of his practice involves the FCPA.
“I spend quite a bit of my time abroad,” Wong told Corporate Crime Reporter in an interview last week. “Last year, I flew almost 300,000 miles on United Airlines. There were a couple of years where I was American Airlines Executive Platinum and United Global Services at the same time.”
“That’s not necessarily something to be proud of.”
“There are only a handful of reported cases every year but the number of reported cases is growing significantly.”
“There are many reasons to believe that is just the tip of the iceberg.”
“For every reported case, there are many active investigations that are not made public until some sort of a court filing.”
“The FCPA is something that companies have to take extraordinarily seriously given the consequences for non compliance.”
“A lot of what I do involves internal investigations on behalf of corporations where no agency necessarily knows about the allegations.”
Wong comes from a family of immigrant scientists and doctors – not lawyers.
“My dad is retired now but he was a professor of molecular biology,” Wong said.
“My parent’s generation is a generation of immigrants.”
“So a country with such a robust legal system and such a litigious society is pretty new to my family.”
“But I never liked science. I always gravitated toward reading and writing and I’ve always enjoyed courtroom drama.”
Do you remember when it was when you said – maybe I’ll apply to law school?
“Actually after college I was a newspaper reporter. I worked at the Columbia Daily Tribune in Missouri where the University of Missouri has a very proud journalism tradition.”
“Writing a news story, writing a lede is something that always just came naturally. I was editor-in-chief of my college newspaper at Pomona College.”
“I worked as a reporter all my summers during college and then was a reporter full time for a little over a year between college and law school.”
“During my time as a reporter I found, as a lot of reporters do, that I was frequently confronting legal issues whether it dealt with covering courts, Freedom of Information or Sunshine Act requests, or trying to force public officials to open the door at meetings where they wanted to kick the public out.”
“I also found that many reporters just didn’t really understand very well the subjects they covered.”
“So actually I applied to law school thinking I would possibly go back into journalism, to use my law degree to gain credibility but to also understand the subject I covered.”
“I had fantasies about being a sort of Linda Greenhouse type.”
“I always enjoyed criminal law and criminal procedure. There were a number of things on my wish list. One of them was to be a federal prosecutor. That was something that had always been toward the top of my list.”
“I saw it as a wonderful way to serve my country and also get some unparalleled experience.”
“As someone whose parents are immigrants, as someone whose parents and many other relatives didn’t easily get citizenship to the United States – it meant a lot to me to have the opportunity to represent the United States.”
[For the complete transcript of the Interview with Michael Wong, see 26 Corporate Crime Reporter 29, July 16, 2012, print edition only.]