Alexa Poletto

ALEXA POLETTO represents individual and corporate clients in connection with internal investigations, regulatory enforcement actions, and prosecutions conducted by agencies including the U.S. Department of Justice (DOJ), the Securities and Exchange Commission, the New York Department of Financial Services, the Financial Industry Regulatory Authority, and the Federal Trade Commission. She regularly advises senior management and boards of directors regarding sensitive enforcement and investigation-related issues including allegations of financial and ethical misconduct.

Alexa has broad experience in a number of industries and her representations include multinational corporations, banks, broker-dealers, insurance companies, credit card operators, sovereign wealth funds, asset management firms, auto and building manufacturers, life sciences companies, travel technology companies, and sports organizations.

Alexa regularly counsels companies and financial institutions on the design and implementation of corporate compliance programs. She has extensive experience working on corporate compliance monitorships, both representing a financial institution subject to a monitor and as counsel to a corporate monitor.  

Alexa has handled matters involving, among other things, alleged bank fraud, insider trading, financial reporting and disclosure issues, FCPA violations, money laundering, sanctions violations, price fixing, and environmental crimes. She regularly advises clients on a range of anti-money laundering (AML), Foreign Corrupt Practices Act (FCPA), and anti-corruption compliance issues, and counsels companies including private equity firms on FCPA and anti-corruption issues in mergers, acquisitions, and joint ventures. She conducts internal investigations involving whistleblower complaints and other allegations of criminal, civil, and ethical misconduct.

Alexa also represents companies facing antitrust enforcement matters or responding to Civil Investigative Demands by the Federal Trade Commission. She has experience representing clients in a range of complex civil and criminal litigation.

A fluent Italian speaker, Alexa is often called on to handle matters in Italian.

Prior to joining Sidley, Alexa served as an attorney adviser for the DOJ through the agency’s Honors Program. Prior to law school, she received her B.A. from the College of William and Mary, and was a Fulbright Scholar in Damascus, Syria.  She spent several years working in the Middle East and speaks conversational Arabic.

Alexa’s work at Sidley includes:

• Advising the Corporate Compliance Monitor of HSBC Holdings plc and its subsidiaries appointed by the DOJ, the UK Financial Conduct Authority, and the Board of Governors of the Federal Reserve System on sanctions matters in connection with the US$1.9 billion resolution of money laundering and sanctions violations.
• Representing Tavistock Corporation in an investigation following the indictment of the firm’s founder and primary investor for insider trading by the U.S. Department of Justice.
• Representing a major sports organization in connection with the DOJ’s indictment of numerous defendants involved in alleged corruption.
• Representing a Chinese bank before the DOJ, and conducting a related internal investigation, in connection with an investigation into alleged sanctions violations and money laundering related to Russia.
• Representing a global bank in connection with a monitorship related to allegations of money laundering and sanctions violations.
• Representing a Mexican financial institution in connection with compliance and regulatory issues.
• Representing a financial services company in connection with a broad investigation by the DOJ into Bank Secrecy Act and anti-money laundering violations in Latin America.
• Representing two insurance providers in an NYDFS investigation into various claims settlement practices, including the companies’ compliance with New York laws and regulations.
• Representing a public media company in connection with an internal investigation into allegations of financial misconduct, including the payment of executive bonuses.
• Representing a Fortune 500 company in connection with an FTC investigation.
• Representing a manufacturing company in connection with a criminal antitrust investigation.
• Representing a Fortune 500 company in connection with a criminal environmental investigation.
• Representing an investment management firm in connection with spoofing allegations.
• Representing an asset manager in connection with an investigation into certain trading practices.
• Representing a major insurance company in designing and building a corporate compliance program.
• Representing an asset management firm in connection with a private equity investment in an emerging market.
• Representing ITRenew, a ZMC portfolio company, in its US$925 million sale to Iron Mountain.
• Representing affiliates of private equity firm Siris Capital Group (sellers) and Pulse Secure (target company) in the sale of Pulse Secure to Ivanti.
• Representing affiliates of private equity firm ZMC in connection with its acquisition of Simeio Solutions from Welsh, Carson, Anderson & Stowe.
• Representing an international company in a breach of contract and fraud suit.

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