Thomas G. Ward

THOMAS WARD represents financial institutions and technology companies in government enforcement investigations, litigation, and regulatory matters. His practice centers on high-impact enforcement and litigation representation — having led civil and criminal litigation at the U.S. Department of Justice and directed enforcement at the Consumer Financial Protection Bureau. He is the only lawyer in private practice to have served as both a political appointee overseeing litigation at DOJ and as a career civil service executive leading enforcement at the CFPB, bringing unparalleled insight into federal and state enforcement strategies across Republican and Democratic administrations. Tom is uniquely positioned to anticipate regulatory and enforcement trends in any political environment.

Tom’s practice encompasses defense in investigations and enforcement actions by federal and state agencies, including the DOJ, FTC, CFPB, state attorneys general, and state financial regulators. He counsels clients on matters involving UDAAP, fair lending, payment processing, fintech innovation, data privacy, False Claims Act investigations, FIRREA actions, and regulatory compliance, as well as supervision examinations and strategic responses to enforcement risks, with a particular focus in emerging technologies as applied to consumer finance, including artificial intelligence and cryptocurrencies. 

Government Leadership Experience

Tom served as Deputy Assistant Attorney General at the U.S. Department of Justice during the first Trump Administration from 2017 to 2020, where he led both civil and criminal matters across the Civil Division’s Consumer Protection, Commercial Litigation, Torts, Federal Programs, and Appellate branches. He managed more than 400 lawyers handling over 1,000 active cases, including Financial Institutions Reform, Recovery, and Enforcement Act (FIRREA) matters and False Claims Act (FCA) investigations. At DOJ, Tom was responsible for establishing the priorities and best practices for defending and settling civil litigation in federal courts nationwide in consultation with the U.S. Attorney Civil Chiefs, as well as supervising and advising on litigation conducted by U.S. Attorneys' Offices in delegated civil actions throughout the federal system. As lead counsel in DOJ’s highest-profile matters, he successfully defended constitutional challenges to major federal financial legislation, tried cases to verdict, and argued in the federal courts of appeals.

Tom subsequently served as Enforcement Director at the CFPB from 2020 to 2021. As the Bureau’s chief law enforcement officer, he was responsible for enforcing the 18 federal consumer financial statutes entrusted to the CFPB by the Dodd-Frank Act and the Consumer Financial Protection Act’s prohibition against unfair, deceptive, and abusive acts or practices (UDAAP). He led 250 enforcement lawyers and staff, setting the priorities and directing strategy for hundreds of investigations spanning every major financial sector, including banks with over US$10 billion in assets, fintech innovators, payment processors, and the major American technology companies. His tenure bridged the Trump and Biden Administrations, providing distinctive understanding of financial enforcement priorities across political transitions.

Both at the DOJ and the CFPB, Tom worked closely with leadership across the federal and state enforcement landscape, engaging in joint investigations and public enforcement actions with attorneys general from all 50 states and the District of Columbia, as well as state financial protection agencies such as the New York Department of Financial Services and the California Department of Financial Protection and Innovation.

Private Practice Background

For nearly two decades prior to his government service, Tom was an enforcement and litigation partner at a leading global litigation firm where he represented clients in complex enforcement investigations and cases, commercial litigation, and criminal proceedings, with a focus on financial and securities litigation, international litigation and investigations, professional liability defense, and bankruptcy litigation. During this time, Tom developed extensive experience in litigation and investigations arising from sophisticated financial and accounting frauds, including in matters involving the DOJ, the SEC, the Commodity Futures Trading Commission, the Federal Deposit Insurance Corporation, and the Public Company Accounting Oversight Board. He served as lead counsel for international financial institutions and investment banks, multiple AmLaw 100 law firms, and major global corporations.

This combination of senior government enforcement experience and sophisticated private practice provides clients with strategic advantages in navigating complex regulatory environments, whether defending against enforcement actions, managing supervision examinations, or designing compliance frameworks to prevent investigations before they begin.

Department of Justice Representative Matters

• On behalf of the Commercial Litigation Branch, counsel in numerous FIRREA actions and investigations involving many of the world’s largest financial institutions based on alleged misconduct arising out of mortgage-backed securities offerings made prior to the financial crisis culminating in the Great Recession. Each of these long-running, complex cases and investigations settled in multibillion-dollar resolutions or proceeded to litigation during Tom’s tenure at the DOJ, ending years of uncertainty for the United States and the financial institutions.*
• On behalf of the Consumer Protection and Commercial Litigation branches, counsel in criminal investigations and affirmative FCA civil litigation against major opioid manufacturers in furtherance of combating the national opioid health crisis. Tom served as lead DOJ counsel on cases pursued jointly by the Consumer Protection and Commercial Litigation branches in coordination with various U.S. Attorneys’ Offices. These cases resulted in the criminal convictions of a major opioid manufacturer and its key employees and multibillion-dollar criminal fraud and FCA civil settlements.*
• On behalf of the Federal Programs branch, counsel in litigation arising from the Puerto Rico debt crisis, the most severe financial crisis faced by a single state or territory in United States history. Tom defended the constitutionality of the Puerto Rico Oversight, Management, and Economic Stability Act (PROMESA), a federal law that provides Puerto Rico the ability to restructure its debt in bankruptcy and allows for expedited approval of critical infrastructure projects. Tom presented oral argument before the U.S. District Court, against and alongside three former solicitor generals, and prevailed in defending PROMESA’s constitutionality, which was ultimately affirmed by the Supreme Court of the United States.*
• On behalf of the Torts branch, counsel in litigation arising from the collisions between the U.S. Navy destroyers USS McCain and USS Fitzgerald and private vessels in separate accidents in 2017, which resulted in Navy casualties and more than $500 million in damages. Tom was responsible for affirmative litigation against the private vessels in the U.S. and Japan, and served as trial counsel, lead negotiator with international legal counsel, and liaison to foreign ministries of justice on behalf of the United States.*

Private Practice Representative Matters

• Counsel for a premier global law firm in litigation and investigations arising from the bankruptcy of the world’s largest independent derivatives execution and clearing firm, which failed following the disclosure of an elaborate, long-running financial fraud. Represented client in multi-district federal court litigation, two federal criminal trials, concurrent U.S. Attorney, SEC, and CFTC investigations, and SEC enforcement actions.*
• Counsel for a major international investment bank in high-profile litigation brought by public pension funds in federal and state court alleging the loss of hundreds of millions of dollars due to an allegedly fraudulent failed securitization of collateralized loan obligations.
• Counsel for the World Bank in connection with fraud and corruption investigations into World Bank-financed projects worldwide. The investigations uncovered pervasive fraud, resulting in debarments, domestic and international criminal referrals, and guilty pleas by World Bank employees to Foreign Corrupt Practices Act violations. Tom also assisted and advised the World Bank in establishing its own internal enforcement office and investigative function, now titled the Integrity Vice Presidency (or INT).*
• Counsel for a prominent global law firm defending against multiple coordinated securities fraud and professional liability actions brought by many of the world’s most sophisticated institutional investors. The plaintiffs purchased bonds issued by the law firm’s former client, a seemingly profitable debt collection company that collapsed following the disclosure of an intricate financial fraud, resulting in criminal convictions and an SEC investigation.*

*The above matters were handled prior to joining Sidley.