Robert M. Appleton

An internationally renowned leader in high-profile, cross-border commercial activity, Robert Appleton advises and defends international and U.S. companies, organizations, and individuals in sensitive government investigations, regulatory enforcement actions, and criminal litigation.

Robert is known for his skill in assisting clients with complex cross-border international challenges and potential issues with U.S. regulators. These include Foreign Corrupt Practices Act (FCPA), complex international fraud, and anti-money laundering investigations and defense, and in OFAC sanctions, CFIUS, global asset recovery, cryptocurrency fraud and recovery, enhanced due diligence of counterparties, and insider trading matters. His experience extends to deep cross-border due diligence of third parties, securities and financial investigations, and whistleblower cases. Robert has led, supervised, or managed more than 1,000 prominent corruption scandal, complex cross-border fraud, and compliance cases spanning 150 countries successfully retrieving more than one billion dollars in stolen assets for clients. Recently, Robert has focused on helping clients navigate the current complex web of Russian and China sanctions environment. Robert has also assisted Latin America-based financial institutions and asset management organizations in recovering funds in the U.S. and abroad, including in the Lava Jato (“Car Wash”) scandal.

With unparalleled and extensive cross-border work, steep experience in OFAC sanctions, FCPA, and AML investigations and defense, and having held senior positions in the U.S. government and the United Nations, Robert maintains strong and effective working relationships with senior government officials at the DOJ, Treasury, and the SEC, Robert solves problems that other lawyers cannot. This experience and his focus on consistently placing clients' goals and needs above all else are invaluable in moving cases forward that might otherwise languish without such an extensive resume. Despite his work's intense nature and complexity, clients praise the ease of working with Robert and his ability to achieve the many successes on their behalf where others may have stumbled.

Robert has held many prominent positions in government and international organizations, including serving more than 13 years as a senior U.S. federal prosecutor in the Department of Justice. He twice received the DOJ's prestigious Director's Award during his tenure. He served in leading enforcement, chief compliance, and legal roles in several international organizations and NGOs, including at the United Nations as chief of the first Anti-Corruption Task Force.

Robert was also lead prosecutor in the DOJ’s case against Pablo Escobar’s principal money launderer, Jose Stroh, and was appointed special counsel and then lead investigations counsel to former Chairman of the Federal Reserve Paul Volcker's Independent Inquiry Committee Investigation into the Iraqi Oil for Food investigation, where he worked closely with Mr. Volcker and supervised the investigations of Saddam Hussein's corruption of the program. At the Global Fund to Fight AIDS, Tuberculosis and Malaria, Robert served as Director of Financial Investigations and Forensic Audit Deputy Inspector General. In private practice, Robert continues to represent clients in noteworthy national and international cases, investigations, and cross-border matters.

Criminal Cases
  • Successfully represented two Brazilians in the Lava Jato cross-border FCPA prosecution led by the Department of Justice in Brazil from 2018 to the present. Succeeded in negotiating a favorable resolution for the clients that saved them from jail time and substantial penalties.
  • Represented a Canadian individual and company in a UN-related prosecution by the DOJ in the Northern District of California. His brief on UN immunity resulted in a dismissal of the charges in the case.  US v. Siciliano (N.D. California).
  • Successfully represented an SEC whistleblower in a cross-border FCPA case.
  • Engaged in one of the first cryptocurrency fraud cases in the bankruptcy courts where the crypto exchange went into bankruptcy. He represented fraud victims of the bankrupt exchange and also a money manager that defrauded numerous clients of more than $1 billion in assets.
  • Represented more than ten companies and at least seven individuals facing federal regulatory investigations and successfully persuaded the DOJ and the SEC not to charge them.
  • Succeeded in referring more than five matters to federal criminal and regulatory authorities who accepted the case, prioritizing the matters after months of self-referrals languishing in the various reporting portal systems.


Speaking Engagements

A pivotal event exploring the aftermath of the wide ranging Lava Jato enforcement actions in Brazil and featuring authorities who were centrally involved in investigating that historic scandal.

Honors & Recognitions

  • Fellow of the prestigious Litigation Counsel of America, an invitation-only trial lawyers’ honorary society. Membership is limited to 3,500 fellows, representing less than one-half of one percent of American lawyers
  • Received more than 20 awards from the U.S. Department of Justice and related agencies, including twice receiving the highly coveted Attorney General's Award for Distinguished Service, the second-highest award given in the DOJ


  • Litigation Counsel of America
  • National Trial Lawyers Association


J.D., magna cum laude, Western New England School of Law, 1989

B.A., cum laude, Emory University, 1985


  • New York
  • Connecticut
  • U.S. Supreme Court
  • U.S. Court of Appeals for the Second Circuit
  • U.S. District Court for the Eastern District of New York
  • U.S. District Court for the Southern District of New York
  • U.S. District Court for the District of Connecticut
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