Michael A. DeBernardis
Locations
Bar Admissions
District of Columbia Maryland
Education
George Washington University Law School, J.D., cum laude, International Law Review University of Delaware, B.B.A.
Michael A. DeBernardis is Chair of the firm's Global Investigations, Enforcement and Compliance practice, Managing Partner of the firm’s Washington, D.C. office, and a member of the White Collar & Regulatory Defense practice group.
Michael assists clients with internal investigations relating to high-stakes matters including bribery and corruption under the Foreign Corrupt Practices Act, procurement fraud, financial and accounting fraud, money laundering, and other ethics issues and violations of company policy. Michael has represented clients in connection with inquiries by the U.S. Department of Justice, U.S. Securities and Exchange Commission and U.S. Senate Permanent Subcommittee on Investigations, among others. Michael works extensively with clients to prevent issues before they arise, assisting American, European, and Asian clients in designing, evaluating, administering, and maintaining anti-corruption, integrity compliance, and corporate governance programs. Michael has substantial experience with corporate compliance monitorships, having served on multiple occasions as an independent compliance monitor, as counsel on behalf of a monitor, or as “buffer counsel” for companies facing monitorships.
Michael also serves as Chair of the firm’s Multilateral Development Bank Investigations and Sanctions practice, where he represents companies and individuals in all phases of MDB sanctions proceedings, from audit and investigation, to litigation of allegations and arguments before sanctions boards, to sanction release proceedings. Michael has represented and counseled clients in connection with proceedings before the World Bank, African Development Bank, Asian Development Bank, European Bank for Reconstruction and Development, and the Inter-American Development Bank.
Michael also represents clients in complex litigation and international arbitration matters, including securities class action litigation, breach of contract claims, and claims resulting from sovereign debt default.
Selected Matters
Investigations and Integrity Compliance
- Conducted multi-year global compliance review of Innospec Inc. on behalf of the Corporate Compliance Monitor appointed by the U.S. Department of Justice, the U.S. Securities & Exchange Commission, and the U.K. Serious Fraud Office
- Representation of Latin American airline in connection with whistleblower report related to potential FCPA violations
- Representation of defense contractor in connection with investigation related to potential ITAR violations
- Representation of financial services firm in connection with internal investigation related to potential FCPA violations in Panama
- Representation of automotive services company in connection with investigation into potential diversion of products to Russia.
- Representation of multinational “supermajor” oil and gas company in connection with anti-corruption compliance audit and investigation of local business partner in South Africa
- Representation of Fortune 500 pharmaceutical company in conducting anti-corruption M&A due diligence in India
- Representation of government contractor in connection with internal investigation allegations of potential financial fraud
- Representation of GOL Linhas Aereas Inteligentes through a Special Committee in connection with investigation of potential claims associated with bankruptcy proceeding
- Representation of high-profile founder/executive in connection with SEC investigation related to statements made on social media
- Representation of auction house in connection with U.S. Senate investigation into potential money laundering and sanctions violations in the industry
- Representation of former partner of a private equity firm in connection with SEC investigation regarding potential violations of the Investment Advisors Act
- Representation of IT specialist in federal criminal prosecution related to unauthorized access for former employer’s computer network
Multilateral Development Bank Investigations and Sanctions
- Representation of Chinese infrastructure company in connection with contested sanctions proceedings by The World Bank, including argument before the Sanctions Board. Sanctions Board Decision No. 88 (Sanctions Case No. 372) issued on June 29, 2016
- Representation of a state-owned construction company in connection with the negotiated resolution of a sanctions investigation by the African Development Bank; assisted the company in negotiating a settlement and meeting its obligations thereunder, resulting in early release from debarment
- Representation of French multinational CAC 40 industrial manufacturing company under a negotiated resolution agreement to resolve a World Bank Group investigation and coordination with the company’s compliance monitor
- Served as independent compliance monitor jointly appointed by African Development Bank and international power company as condition for release from 36-month debarment
- Representation of engineering company in connection with successful resolution of investigation by Asian Development Bank related to alleged bidding fraud
- Served on behalf of monitor appointed by World Bank to evaluate the integrity compliance program for a $100 billion construction company in connection with 34-month sanction
- Representation of large EPC company in connection with investigation and sanctions proceeding by the Inter-American Development Bank related to potential fraud in connection with a tender in Ecuador
- Representation of multinational construction company in connection with investigation by the European Investment Bank into potential fraud
Other Select Enforcement and Litigation Matters
- Representation of U.S. defense contractor in arbitration against Bolivarian Republic of Venezuela for breach of contract
- Representation of investor group in connection with action brought in relation to sovereign debt default
Recognitions
- Recognized as a Law360 2021 "Rising Star"
- Recognized in Washington DC Super Lawyers as a 2018 Rising Star
- 2018 – 2019 Capital Pro Bono High Honor Roll, sponsored by the District of Columbia Court of Appeals and the Superior Court of the District of Columbia
- 2013 – 2015, 2017 Capital Pro Bono Honor Roll, sponsored by the District of Columbia Court of Appeals and the Superior Court of the District of Columbia
- 2011 – 2012 Capital Pro Bono High Honor Roll, sponsored by the District of Columbia Court of Appeals and the Superior Court of the District of Columbia
Highlighted Publications and Lectures
Co-author, with Laura Perkins and Katherine Taylor, “Suspect Corrupt Payments? How to Navigate Potential Corporate Crisis,” The Review of Securities & Commodities Regulation, p. 171-176, September 2024
Co-author, with Kevin Abikoff, Laura Perkins and Christine Kang, “Spotlighting Multilateral Development Bank Monitorships,” GIR's The Guide to Monitorship 4th Edition, May 2024
Co-author, "Bribery Settlement Gives Insight On DOJ Policies," Law360, January 5, 2024
Select Podcasts
- “Navigating Compliance Challenges in Venezuela’s Energy Sector,” Hughes Hubbard & Reed All Things Investigations Podcast, Compliance Podcast Network, Podcast Episode 79, January 12, 2026
- “DOJ’s Evolving Guidelines: Implications from Liberty Mutual’s FCPA Case,” Hughes Hubbard & Reed All Things Investigations Podcast, Compliance Podcast Network, Podcast Episode 75, August 25, 2025
- “FCPA Enforcement: What the New Guidelines Mean with Mike DeBernardis,” Hughes Hubbard & Reed All Things Investigations Podcast, Compliance Podcast Network, Podcast Episode 73, June 18, 2025
- “Considerations for FCPA Trials with Mike DeBernardis,” Hughes Hubbard & Reed All Things Investigations Podcast, Compliance Podcast Network, Podcast, Episode 70, March 31, 2025
- “Implications of Trump’s FCPA Executive Order with Mike DeBernardis,” Hughes Hubbard & Reed All Things Investigations Podcast, Compliance Podcast Network, Podcast, Episode 68, February 19, 2025
- “Anchored in Fraud: Mike DeBernardis and Shayda Vance on Austal USA’s Scandal,” Hughes Hubbard & Reed All Things Investigations Podcast, Compliance Podcast Network, Podcast, Episode 57, September 23, 2024
- “Compliance Lessons from Gunvor and Trafigura Enforcement Actions with Mike DeBernardis,” Hughes Hubbard & Reed All Things Investigations Podcast, Compliance Podcast Network, Podcast, Episode 50, April 15, 2024
- “The Albemarle FCPA Enforcement Action with Mike DeBernardis,” Hughes Hubbard & Reed All Things Investigations Podcast, Compliance Podcast Network, Podcast, Episode 41, November 27, 2023
- Co-Host with Tom Fox, The Corruption Files Podcast, 2 Seasons (2022-2024).
- “Creating and Maintaining an Ethical Culture with Laura Paredes,” Hughes Hubbard & Reed All Things Investigations Podcast, Compliance Podcast Network, Podcast, Episode 27, May 8, 2023
Court Admissions
- United States Court of Federal Claims
- United States District Court for the District of Columbia
News & Insights For Michael A. DeBernardis
View All News & InsightsMichael DeBernardis Examines Rules of Evidence in MDB Sanctions Proceedings
Michael DeBernardis examines the rules of evidence in multilateral development bank (MDB) sanctions proceedings in the second edition of Global Investigation Review’s Guide to Multilateral Development Bank Investigations.
Month in a Minute: December 2025 and January 2026
Highlights from December 2025 and January 2026 include a guilty verdict for a Texas businessman, a sentence and forfeiture agreement for a former oil trader and dropped charges in a case related to the Petrobras bribery scheme.
Hughes Hubbard Advising Grab on its Agreements to Acquire Digital Investing Platform Stash Financial
Hughes Hubbard is advising Grab Holdings Limited on its definitive agreements to acquire 100% of the equity interest in Stash Financial, Inc.
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