Sean Freeh   [Download VCard]
Associate

Sean Freeh is an Associate at Freeh Sporkin & Sullivan, LLP (“FSS”), working from the Wilmington, Delaware office. Sean joined FSS in October 2020.

Prior to joining FSS, Sean served in the United States Army where he served as an Army Ranger. In his capacity, Sean operated within the United States Army Special Operations Command and after five years of service was honorably discharged at the rank of Captain. Following his completion of military service and while attending law school, Sean was a Judicial Intern to the Honorable Loretta A. Preska of the Southern District of New York. Sean also served as a Summer Associate at Dechert LLP, in Washington, D.C.

In Sean’s role as an FSS Associate, he supports engagements on a global basis. Several of his recent notable assignments include:

• Providing support in an international money-laundering investigation.
• Supporting an investigation and background due diligence for a Board of Directors, evaluating policies and procedures for adequacy.
• Assisted in the internal investigation of a sports team to gather facts and back report to the owners.
• Evaluated security systems, protocols, and resources associated with a non-profit organization that had been receiving threats. Provided appropriate guidance to mitigate risk.

Sean is a graduate of the Georgetown University School of Foreign Service and the Georgetown University Law Center. Sean is admitted to the District of Columbia bar.

Walt Donaldson   [Download VCard]
Chief Operating Officer

Walter Donaldson is the Chief Operating Officer for Freeh Sporkin & Sullivan, LLP (“FSS”). Walter brings over 40 years of executive management experience to the law firm, overseeing security divisions, investigative groups, compliance and operations personnel. He has managed multi-million dollar annual budgets and global divisions for Fortune 50 corporations. Walter has overseen complex international fraud and regulatory cases; his experience spanning five continents in 57 countries including matters involving cybercrime, computer forensics, bribery and corruption, BSA/AML/OFAC compliance, FCPA regulatory violations and testing, M&A due diligence investigations, security reviews and corporate investigations.

Walter was previously the Managing Director and the licensed private investigator for Freeh Group International Solutions, LLC. He served in that capacity from 2010 to 2020. During that time he traveled globally managing client engagements ranging from corporate fraud, bribery and corruption investigations, data breach & incident response investigations, compliance & regulatory reviews related to FCPA, AML/CTF/OFAC and cryptocurrency. He performed risk / security assessments of corporations / institutions for higher education and executive homes/retreats. He provided and managed executive protection details, Red Team physical security operations, active shooter response education, event security planning and also oversees the firms computer forensic engagements among other areas of expertise.

From 2006 to 2010, Walter served as the Global Special Investigations Director for Bank of America / Merrill Lynch. He was responsible for the special investigations division, cybercrime investigations division, Merchant Fraud division, and identity theft investigations. Walter also had responsibility for all of physical security operations across Canada. He also worked with the International Association of Chiefs of Police (IACP) to design and implement their national “Model Policy” for investigating identity crimes across the United States. From 2008-2010 Walter served as the U.S. Representative to INTERPOL for global cyber and payment card crimes at its General Secretariat headquarters in Lyon, France. After retiring in 2010 from Bank of America, Walter joined FGIS.

From 1987 to 2006, Walter served as the Global Director of Corporate Investigations for MBNA America. He managed all investigative offices globally as well as the executive protection for principles in the U.S. and Mexico. Walter oversaw corporate fraud auditing and regional / country risk assessments for both vendors and new corporate operations. He established some of the first computer forensic labs in the U.S., Canada and the U.K. Walter served as the Global Director of investigations for twenty years before the company’s acquisition by Bank of America.

Walter is a Veteran of the United States Coast Guard and graduate of the Coast Guard, Maritime Law Enforcement Academy. He received an honorable discharge following the completion of his tour of duty. However, he remains active with the Coast Guard Tactical Law Enforcement Association. Walter holds multiple professional security and compliance certifications and maintains an active U.S. government security clearance. Walter currently serves as a member on several Board of Directors including the Vidocq Society, where he is a member of the board and also serves as the CISO. The Vidocq Society provides law enforcement with pro bono expertise in the investigation of cold case homicides. Walter maintains an office in Greenville, Delaware.

The Honorable Eugene R. Sullivan   [Download VCard]
Senior Partner

Eugene R. Sullivan is a retired Federal Judge in Washington D.C. with over 16 years of appellate experience. Nominated by President Reagan and confirmed by the Senate, Judge Sullivan was installed as a Federal Judge in 1986. In 1990, President Bush named him the Chief Judge of the U.S. Court of Appeals (AF). In 2002, he was elevated to Senior Status. When not recalled to active Court service, Judge Sullivan is a partner in the D.C. Law firm of Freeh Sporkin & Sullivan LLP.

Born in St Louis, Missouri, Judge Sullivan graduated from the United States Military Academy, West Point, New York, where he was a member of the Cadet Honor Committee (elected by his class) and the varsity lacrosse team. Following graduation, he served in the Army for five years and qualified as a tanker, an Airborne Ranger, a Ranger Instructor and a Jumpmaster. He was awarded the Bronze Star, the Air Medal and other decorations in Vietnam. Judge Sullivan has been inducted into the U.S. Army Ranger Hall of Fame.

After the Army, Judge Sullivan graduated from Georgetown University Law Center, serving as an editor of the Georgetown Law Journal in his senior year. After law school, Judge Sullivan clerked for Chief Judge Matthes of the United States Court of Appeals (8th Circuit) and worked for the Patton Boggs law firm in Washington, D.C.

Judge Sullivan served in the White House on the legal defense team of President Nixon during the Watergate investigation. For eight years, he was in the U.S. Department of Justice, Washington, D.C. Later before he became a Federal Judge, Judge Sullivan served in the Pentagon for almost five years as the Air Force General Counsel and the Chief Ethics Officer of the U.S. Air Force after serving initially as the Deputy General Counsel.

In addition, Judge Sullivan was the General Counsel of the National Reconnaissance Office (“NRO”-a then super-secret US satellite intelligence agency). While in the Air Force, he was the Governor of Wake Island (the U.S. possession in the Pacific). Judge Sullivan served on the Federal Commission to review the West Point Honor Code. He is a Trustee Emeritus and the founding Chair of the Ethics Committee of the West Point Board of Trustees (Association of Graduates) and served on the Executive Board of the Duke Law School Center for Law, Ethics and National Security. In 1990 he was appointed to the Administrative Conference of the USA.

Judge Sullivan has given many lectures on American law to visiting international judges and lawyers. For many years, he was the chair of the International Judicial Conference (Criminal Law) and the Great Debate (on judicial reform) between the USA and England. For promoting the rule of law and for service to the Nation, Judge Sullivan has been awarded the Medal of Justice from Romania, the First Class Medal of Defense from Hungary, the Defense Minister’s Citation of Merit from the Republic of China, a Doctor of Law degree(Hon)from New England School of Law, the Air Force Exceptional Civilian Service Medal, the Defense Department Medal for Distinguished Public Service, the 2001 Castle Award and the 2017 William Tudor Sword(The Castle and Tudor Awards are given to one West Pointer each year for Service to Country). Judge Sullivan is a recipient of the Ellis Island Medal of Honor.

He has 2 published novels, both political thrillers: The Majority Rules (2005) & The Report to the Judiciary (2008) and was the Chief Judge of the Judging Panel(16 years)for the annual International Dublin Literary Award (100,000 Euros for a single work of fiction). Judge Sullivan is married to Lis Sullivan from Denmark who is an artist and field anthropologist (expertise in bound-foot women of China). Their Daughter, Kim, is a graduate of Columbia University, attended graduate school at Columbia University, and is a CNBC producer (photo) in New York City; Eugene II, their son, is a litigator in Washington DC and is a graduate of Duke University, The London School of Economics, and Columbia Law.

Thomas McC. Souther   [Download VCard]
Partner

Thomas McC. Souther is a partner at Freeh Sporkin & Sullivan, LLP, resident in the New York office, having rejoined the firm in January 2018. His current practice concentrates in the areas of government and regulatory investigations, white collar criminal defense, and internal investigations. He has considerable experience in both the trial and appellate courts. He served for four years as an Assistant United States Attorney in the Southern District of New York, where he investigated and prosecuted a wide variety of criminal cases, including bank fraud, commodities fraud, and mail and wire fraud.

Prior to returning to the firm, Mr. Souther was a partner in the White-Collar Litigation and Investigations Practice Group of Pepper Hamilton LLP. He previously was a partner for 15 years in the white-collar practice of a prominent US-based global law firm.

Mr. Souther recently led the team of attorneys, investigators, and data analytics experts assembled by Louis J. Freeh following Mr. Freeh’s appointment as a Special Master by the U.S. District Court for the Eastern District of Louisiana in a multidistrict litigation matter involving a major settlement program supervised by the district court. He also served as a principal adviser and strategist to Mr. Freeh in his role as the Chapter 11 Trustee of MF Global Holdings Ltd. and various of its subsidiaries.

Mr. Souther’s experience has included advising public and private corporations, boards of directors and special committees, and representing directors, corporate executives, and other individuals in connection with internal investigations, regulatory inquiries, grand jury investigations, and criminal prosecutions. Mr. Souther successfully defended at trial in federal district court in Massachusetts a former executive of a pharmaceutical company charged with violating the anti-kickback statute, and won the acquittal at trial in the Southern District of New York of a former employee of Bankers Trust Company who had been charged with misapplication of bank funds. He also advised a publishing and media company in connection with a criminal investigation in the Eastern District of New York relating to circulation fraud, and negotiated a non-prosecution agreement on behalf of the company that avoided prosecution of the company and its subsidiaries.

In addition to his experience in the white-collar defense and regulatory areas, his practice also has included work on a variety of civil matters, including general corporate and complex commercial litigation, and banking-related matters.

Mr. Souther graduated from Bucknell University in 1980 and received his law degree from Fordham University School of Law in 1984.

Representative Engagements

• Served as the independent monitor of a fixed-income fund pursuant to a cease and desist order entered by the U.S. Securities and Exchange Commission as part of a settlement agreement between the SEC and the fund.
• Representation of a global compliance officer of a foreign bank in connection with a criminal and regulatory investigation of alleged violations of OFAC regulations.
• Internal investigation of an international network solutions company in connection with allegations of accounting irregularities and the timing of income and expense recognition.
• Representation of a compliance officer of a U.S.-based global financial institution in connection with a grand jury investigation of certain trading activity at the institution.
• Representation of a former employee of a foreign bank in connection with a criminal and regulatory investigation of alleged violations of OFAC regulations and U.S. sanctions.
• Representation of a former employee of a pharmaceutical company in connection with a criminal and civil investigation by the U.S. Department of Justice of alleged violations of the anti-kickback statute.
• Representation of a developer of a luxury resort in connection with a criminal investigation related to wire fraud and money laundering, and subsequent criminal forfeiture proceedings.
• Representation of a senior executive of a foreign bank in connection with a criminal investigation of alleged violations of OFAC regulations.
• Representation of an individual charged with wire fraud and money laundering conspiracy in connection with a government loan program.
• Representation of a hedge fund principal in connection with a criminal investigation of alleged insider trading.
• Representation of several hedge funds in connection with various criminal and regulatory investigations arising out of the 2008 financial crisis.
• Representation of several current and former employees of a pharmaceutical company in connection with a criminal and civil investigation by the U.S. Department of Justice of alleged off-label drug promotion.
• Representation of a senior executive in the U.S. office of a foreign bank in connection with a criminal and regulatory investigation involving the bank and several of its customers.
• Representation of several senior executives and members of the board of directors of a public company in connection with an internal investigation of related party transactions; representation of the executives and directors in subsequent shareholder derivative litigation.
• Representation of senior management of a foreign-based global financial institution in connection with an internal and regulatory investigation relating to anti-money laundering policies and procedures.
• Representation of a former employee of a foreign bank in connection with an internal investigation and subsequent criminal investigation of alleged violations of OFAC regulations.
• Internal investigation of a major industrial supply company in connection with allegations of related party transactions.
• Representation of the former controller of a major equipment leasing company in connection with an internal investigation, and subsequent SEC and criminal investigations, of alleged securities fraud.
• Representation of a major accounting firm and its employees in connection with criminal and regulatory investigations of alleged backdating of options at a public company.
• Representation of hedge funds in connection with various investigations by the New York Attorney General relating to alleged violations of the Martin Act.

Eugene R. Sullivan II   [Download VCard]
Partner

Eugene R. Sullivan II is a partner at Freeh Sporkin & Sullivan, LLP, in its Washington, D.C. Office.

Mr. Sullivan represents businesses and individuals facing investigation by federal and state law enforcement authorities and provided counsel on compliance and control issues. He has served as counsel to a court-appointed monitor reviewing Foreign Corrupt Practices Act compliance issues in the global operations of a Fortune 100 company

He served on the investigative team of the independent, internal investigation of publicized allegations of sexual abuse at the facilities of a major university and the alleged failure of the university’s personnel to report such sexual abuse to appropriate police and government authorities.

He has also conducted an internal investigation for an international governing body into allegations of bribery and corruption.

Mr. Sullivan also was a litigator at Howrey, LLP in its International Trade and Intellectual Property Litigation Division. He specialized in patent litigation in U.S. district courts and before the International Trade Commission under Section 1337 of the Tariff Act of 1930. Mr. Sullivan also has worked in the London office of a global law firm where he specialized in U.K. and U.S. intellectual property litigation. He has represented multinational entities in disputes relating to infringement of intellectual property rights, protection of confidential information and licensing.

After graduation from the London School of Economics, Mr. Sullivan held judicial clerkships in London with Master Michael McKenzie, Q.C. of the Royal Court of Appeal (Criminal Division) and with His Honor Judge Graham Boal, Q.C. of the Central Criminal Court (The Old Bailey). After graduating from Columbia Law School, he served a judicial clerkship with Chief Judge H.R. Mayer in the U.S. Court of Appeals for the Federal Circuit.

Mr. Sullivan co-founded and was the first General Counsel of the No Greater Sacrifice Foundation, a nonprofit that provides college scholarships to the children of military members killed in action in the war against terrorism.

Mr. Sullivan is a graduate of Duke University (B.A. history), the London School of Economics (LL.B. with upper second class honors) and Columbia Law School (LL.M).

Mr. Sullivan is a member of the New York and District of Columbia bars.

Gregory A. Paw   [Download VCard]
Partner

Gregory A. Paw is an accomplished trial lawyer with extensive white collar investigation and defense experience. A former federal prosecutor and past director of the New Jersey Division of Criminal Justice, Greg now is a partner with Freeh, Sporkin & Sullivan. Drawing on his unique international law enforcement work investigating regime war crimes in Iraq, Greg now provides the benefit of his experience in criminal litigation and knowledge of international compliance and risk management to advise clients on enforcement and compliance issues arising in international business. Clients have described Greg as “exceptional” and a “very effective communicator” who is “practical” and “unflappable.”

In recent years, Greg has served as counsel on a wide array of special investigations along with Louis J. Freeh, the former Director of the Federal Bureau of Investigation. He also has led global engagements where he has implemented, evaluated and improved compliance and risk management programs for multi-national companies. For example, Greg recently successfully guided a multi-national medical device company through federal monitorships under the Anti-Kickback Statute and FCPA and designed effective and best-in-class compliance remediations across Latin America. He also:

• has served as legal counsel to a court-appointed monitor of Daimler/Mercedes-Benz, evaluating and reviewing the company's world-wide anti-corruption efforts. In this role, Greg engaged in extensive evaluation work in Latin America, Europe and Asia.
• is advising a prominent international developer concerning sanctions imposed by the U.S. Office of Foreign Assets Control (“OFAC”) and current criminal investigations in the United States and United Kingdom.
• is reviewing compliance controls at a multinational oil & gas company and advocating for the company before the U.K. Serious Fraud Office.
• provided legal counsel to the Special Master appointed by the U.S. District Court in Louisiana, providing guidance to the investigation of allegations of improper conduct and false claims filed in the BP Deepwater Horizon claims settlement process — the largest court-supervised settlement program in U.S history.
• served as legal counsel to an investigation of a major university in the wake of a former coach being charged with crimes against children. Greg prepared a report that has been called a "landmark" for issues of university governance.
• investigated corruption allegations concerning a former member of FIFA's executive committee, who was banned for life from all FIFA and football related activities by an action of the FIFA Ethics Committee.

Greg served as a federal prosecutor in the Philadelphia U.S. Attorney’s Office from 1997 to 2006. He also volunteered to serve in Iraq from 2004 to 2005 as deputy chief of the team of U.S. prosecutors and investigators tasked to help the Iraqi government in the prosecution of former senior Iraqi officials with war crimes and crimes against humanity. He also served as the director of the New Jersey Division of Criminal Justice, supervising a state-wide law enforcement office composed of prosecutors and investigators.

Prior to joining the Justice Department, Greg served as a special counsel to the U.S. House of Representatives investigation concerning alleged misconduct during the 1980 Presidential election. He also served as special counsel to an Independent Counsel’s investigation of alleged misconduct during the 1992 Presidential election.

Greg is admitted to practice in New Jersey, New York and the District of Columbia. He obtained his law degree from the College of William & Mary, and his undergraduate degree from the University of Illinois. He served as a judicial clerk for the Honorable Walter E. Hoffman, U.S. District Court for the Eastern District of Virginia.

Greg is a trustee at the Moorestown Friends School, a Quaker-based institution. He also serves on the finance committee of the Forman S. Acton Educational Foundation, which advances educational opportunities for students in Salem, New Jersey.

Ronald Noble   [Download VCard]
Partner

Ronald K. Noble joined FSS as Senior of Counsel on 8 July 2016.

He is also the founder of RKN Global DWC-LLC, a risk management and business development firm enhancing the security of countries, their citizens, and businesses.

Between 2000-2014, Noble was elected three times to serve as INTERPOL Secretary General. He was elected two times unanimously, and he became the first official to visit all of its 190 member countries. He transformed INTERPOL into a global, 24/7 enterprise–regularly deploying Incident Response Teams (IRTs) worldwide to confront serious crimes, terrorist attacks, and natural disasters.

Between 1993-1996, Noble served as Assistant Secretary and then Under Secretary for Enforcement of the US Treasury Department, with direct responsibility for the US Secret Service, US Customs Service, FinCEN, the Bureau of Alcohol Tobacco & Firearms, the Office of Foreign Assets Control (OFAC), and other agencies. He was unanimously confirmed as Treasury Assistant Secretary by a Democrat-controlled U.S. Senate in 1993 and then as Treasury Under Secretary by a Republican-controlled U.S. Senate in 1995. Upon his departure, he received the U.S. Treasury Department’s highest award – the Alexander Hamilton medal.

Between 1996 and 2014, Noble was also a law professor at New York University; he became a fully tenured professor in 1999.

Between 1984 and 1989, Noble served first as an Assistant US Attorney for the Eastern District of Pennsylvania and then served as a Chief of Staff and Deputy Assistant Attorney General in the U.S. Department of Justice’s Criminal Division.

Noble received his BA from the University of New Hampshire and Juris Doctorate from Stanford Law School. He served as Articles Editor on the Stanford Law Review and was elected President of his graduating class in 1982.

Noble was named to France’s Legion of Honor, knighted by the Vatican and received high honors from several countries. He received the U.S. Department of Homeland Security’s highest honor in November 2014 and was awarded the Ellis Island Medal of Honor in June 2016.

Noble is married to Marjam Lindsbro and has one son, Maximillian.