DAVID LUDLOW has extensive experience representing companies and individuals in government enforcement actions, litigation, internal investigations and compliance counseling matters.
He has handled numerous U.S. Department of Justice (DOJ) criminal and civil investigations, litigation matters and internal investigations involving, for example, healthcare fraud, the Foreign Corrupt Practices Act (FCPA), the federal Anti-Kickback Statute, off-label promotion and marketing practices, pricing and reimbursement, data integrity, QSR/GMP issues, clinical trial and laboratory practices, and product tampering and diversion. David has a breadth of experience handling cross-border matters in Europe, China, Asia, the Middle East and South America.
David’s practice also includes counseling corporations about their corporate compliance programs, conducting program reviews, risk assessments, employee training, M&A and contractor due diligence, and policy/procedure development.
Illustrative of the depth of David’s practice, his recent engagements include:
- Successfully obtaining DOJ and UK Serious Fraud Office declinations to prosecute for a multinational life sciences company in a matter involving anticorruption issues in China
- Successfully obtaining DOJ declinations for multinational life sciences company in civil qui tam investigations conducted by Eastern District of Pennsylvania and District of Massachusetts
- Successfully obtaining DOJ declination for a multinational pharmaceutical company in a criminal and civil data integrity and good manufacturing practices investigation conducted by District of New Jersey
- Representing a multinational life sciences company in qui tam investigation and litigation conducted by Southern District of New York
- Conducting an extensive product tampering investigation for a multinational consumer product company in coordination with local and federal authorities
- Conducting anticorruption risk assessments for multinational life sciences company at affiliate sites, including in China, Colombia, Germany, India, Poland, Russia, Saudi Arabia, Singapore and Taiwan
- Conducting anticorruption due diligence on a potential acquisition target in China
Admissions & Certifications
- U.S. Court of Appeals, Federal Circuit
- U.S. District Court, District of Columbia
- District of Columbia
- New York
- Brigham Young University - J. Reuben Clark Law School, J.D., 2003 (cum laude)
- Brigham Young University, B.A., 1999 (cum laude)