Thomas G. Ward

THOMAS WARD represents global financial institutions, technology companies, payment networks, private equity firms, and other regulated businesses in high-stakes government investigations, enforcement actions, complex litigation, and regulatory compliance and supervisory matters. His practice frequently involves matters before the U.S. Department of Justice, the Consumer Financial Protection Bureau, prudential bank regulators, and state attorneys general and financial regulators.

Tom brings rare senior government experience to these matters. He is the only lawyer in private practice to have served both as a political appointee at the U.S. Department of Justice—serving as Deputy Assistant Attorney General during the first Trump Administration—and as a career civil service executive at the Consumer Financial Protection Bureau, where he was the CFPB’s Enforcement Director. He also served through both Republican and Democratic administrations, providing him with distinctive insight into federal enforcement priorities and regulatory decision-making across the political spectrum.

Government Leadership

At the U.S. Department of Justice, Tom supervised nationwide civil and criminal litigation strategy across the Civil Division’s Consumer Protection, Commercial Litigation, Federal Programs, Torts, and Appellate branches. He oversaw more than 400 lawyers and staff handling over 1,000 active matters, including significant FIRREA and False Claims Act investigations involving the world’s largest financial institutions, and worked closely with U.S. Attorney Civil Chiefs to establish national litigation and settlement priorities. He personally defended constitutional challenges to major federal legislation, tried cases to verdict, and argued before the federal courts of appeals.

Tom later served as Enforcement Director of the Consumer Financial Protection Bureau, acting as the Bureau’s chief law enforcement officer. At the CFPB, he led the nation’s largest consumer financial enforcement division and directed investigations and litigation involving national banks, fintech platforms, global payment networks, credit reporting agencies, mortgage and auto lenders, and technology platforms offering financial products. He set the enforcement strategy for the Consumer Financial Protection Act and the eighteen federal consumer financial statutes entrusted to the CFPB, including the Bureau’s authority to prohibit unfair, deceptive, or abusive acts or practices.

Private Practice

In private practice, Tom represents clients in their most critical government investigations, enforcement actions, complex litigation, compliance matters, and supervisory engagements. He regularly advises clients facing investigations and enforcement proceedings brought by federal and state regulators and enforcement authorities.

Tom has extensive experience as a trial lawyer and litigator in complex financial and commercial disputes. Over the course of his career, he has represented global financial institutions, Fortune 500 companies, professional services firms, and other major organizations in high-stakes civil litigation, regulatory enforcement matters, and parallel civil, criminal, and regulatory proceedings. He has served as lead trial counsel in complex litigation and has extensive experience litigating cases involving parallel civil, criminal, and regulatory proceedings. His litigation experience includes cases involving allegations of financial and accounting fraud, professional liability, securities-related claims, and other complex disputes arising in highly regulated industries, often involving coordinated multi-jurisdictional proceedings before multiple regulators.

Tom works closely with general counsels, senior executives, and corporate boards to assess enterprise risk, including operational and reputational risk, respond to government investigations, navigate supervisory scrutiny, and develop strategies for resolving complex regulatory and litigation matters. He also advises institutions on institution-wide risk assessments, regulatory remediation, and the development of compliance frameworks for companies entering newly regulated markets or deploying new financial products and technologies.

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.