Keith Rosen

Keith Rosen
Biography
Keith M. Rosen is a partner in Norton Rose Fulbright's Washington, DC office and is the US Head of Risk Advisory.
Keith is an experienced advocate whose practice focuses on Foreign Corrupt Practices Act (FCPA) and other cross-border corporate investigations, white collar criminal defense, False Claims Act investigations and litigation, Congressional investigations and ABC compliance. He has represented clients through multi-agency and multi-jurisdictional investigations around the globe, and has worked across industry sectors, including aviation, energy and healthcare.
Prior to joining us, Keith spent over ten years in the U.S. Department of Justice. From 1999 – 2005, he was an Assistant US Attorney, and from 2007 – 2012, he was the Chief of the Criminal Division for the US Attorney's Office for the District of Delaware. In that capacity, he managed the legal work of the Criminal Division and supervised all appeals in criminal cases before the US Court of Appeals for the Third Circuit.
As the Head of our Risk Advisory practice in the United States, Keith helps lead a global team that provides clients with a holistic, strategic approach to compliance risk management. In that role he has conducted compliance risk assessments, designed compliance policies, provided training on ABC and related issues and advised on compliance diligence issues in business transactions. As a litigator, Keith has handled cases involving health care fraud, securities fraud, insider trading, public corruption, sanctions enforcement, tax fraud and economic espionage. He has also litigated complex issues involving classified information under the Classified Information Procedures Act (CIPA). Keith has successfully tried numerous criminal cases to verdict, and has briefed and argued many appeals.
Professional experience
Representative experience
Representative experience
Cross-Border Anti-corruption and Sanctions investigations
- Represented Canadian aviation company in connection with parallel US DOJ, UK Serious Fraud Office, and Canadian RCMP corruption investigations relating to transactions in Asia. Case declined by the US DOJ with no charges brought.
- Conducted cross-border internal investigation for North American medical device manufacturer in response to whistleblower allegations of FCPA and export control violations in China. Responded to related US SEC inquiry. SEC file closed with no action taken.
- Represented European materials company in connection with a US OFAC investigation involving transactions by its Asian subsidiary.
- Represented Chilean public company in connection with parallel US DOJ and SEC FCPA investigations, resulting in Deferred Prosecution Agreement.
- Represented US aerospace company in connection with criminal FCPA investigation. Case declined by the US DOJ with no charges brought.
- Represented chairman of Japanese company in connection with FCPA investigation and parallel civil and regulatory investigations.
White collar Defense and Regulatory Enforcement
- Represented founder and Chief Medical Officer of medical technology company in connection with parallel civil and criminal False Claims Act and Anti-Kickback Statute investigations.
- Represented US trading arm of a multinational energy company in connection with a US DOJ insider trading investigation.
- Represented Canadian company in connection with a US DOJ False Claims Act investigation relating to the company’s US government contracting. Investigation closed with no complaint filed.
- Represented clean energy developer in connection with a US DOJ False Claims Act investigation. Complaint declined by the DOJ and subsequently dismissed.
- Represented Silicon Valley public company in connection with multiple Congressional, FTC, and State Attorney General inquiries relating to alleged data security and privacy violations.
- Represented US public company in connection with criminal US DOJ/FDA inquiry into alleged misbranded nutritional supplements. Case resolved by Non-Prosecution Agreement.
- Represented CFO of US company investigated by the DOJ for alleged civil False Claims Act and FIRREA violations. No charges brought against the client at the end of the investigation.
- Represented employee of Japanese auto parts manufacturer in connection with criminal antitrust investigation. Case concluded with no charges brought against the client.
- Represented owner/operator of North Carolina gaming/amusements distributor in connection with illegal gambling investigation and prosecution. Charges against the owner were ultimately dismissed
- Represented Texas healthcare provider in connection with parallel state and federal fraud investigations.
Risk Advisory and compliance advice
- Advised US telecommunications technology company on the development and implementation of a new compliance program.
- Advised pediatric research hospital on compliance policy design and development of a risk assessment tool for international business partners.
- Advised US and Canadian affiliates of major European infrastructure development and construction company in the design, development, and implementation of an anti-crime and anti-corruption compliance program, including a compliance risk assessment review and report.
- Advised one of Turkey's largest corporations regarding the development and implementation of an international compliance program, including anti-corruption and anti-money laundering advice, OFAC and EU sanctions advice as well as establishment of general compliance policies and procedures for the corporation and its subsidiaries.
- Advised US private equity firm on anti-corruption issues in connection with multiple investments in South America.
- Advised global energy company on anti-corruption due diligence issues in connection with assets in Africa.
- Represented a major Turkish conglomerate in connection with designing and initiating an anti-corruption compliance program.
Congressional investigations
- Represented large insurance company in connection with Senate committee investigation.
- Represented multiple corporations and their senior executives in connection with Congressional investigations into the administration of the Department of Energy's loan guarantee program.
- Represented multiple bank executives in connection with investigation by Senate subcommittee.
National security / CIPA litigation
- Represented former State Department analyst charged under the Espionage Act with disclosing classified information to the press.
- Represented former AIPAC official charged under the Espionage Act. All charges dropped before trial.
Rankings and recognitions
Rankings and recognitions
- Legal 500 US, Recommended lawyer: Corporate investigations and white-collar criminal defense, The Legal 500, 2024
- The Best Lawyers in America - Criminal Defense: White-Collar, Best Lawyers, 2022 - 2025
Education
Education
- JD, Yale Law School, 1997; Senior Editor, Yale Law Review
- AB, magna cum laude, Brown University, 1993
Admissions
Admissions
- District of Columbia Bar
- Pennsylvania State Bar
Publications
Publications
- Co-author, “New DOJ FCPA guidance focused on vindicating US interests abroad,” Norton Rose Fulbright Legal Update, June 2025
- Co-author, “US DOJ announces new white-collar enforcement plan,” Norton Rose Fulbright Legal Update, May 2025
- Co-author, “ESG and internal investigations: New compliance challenges,” Norton Rose Fulbright Legal Update, April 2025
- Co-author, "2025 Annual Litigation Trends Survey confirms an unpredictable regulatory landscape after Loper Bright," Norton Rose Fulbright Legal Update, February 2025
- "Trump's Regulatory Agenda Looms Over Compliance in 2025," Law360, January 1, 2025
- Co-author, “Second Circuit defers to executive will on application of sovereign immunity,” Norton Rose Fulbright Legal Update, November 2024
- Author, "Compliance Under the Second Trump Administration: The Only Thing Certain Is Uncertainty," Corporate Compliance Insights, November 15, 2024
- Co-author, “The race is on … The DOJ Corporate Whistleblower Awards Pilot Program pits whistleblowers versus companies in a race to the DOJ to report criminal misconduct,” Norton Rose Fulbright Legal Update, August 6, 2024
- Co-author, “DOJ’s new whistleblower pilot program focused on corporate misconduct,” Norton Rose Fulbright Legal Update, March 13, 2024
- Co-author, “New EU Anti-Corruption Framework: what does this mean for multinationals and their compliance programmes?,” Norton Rose Fulbright Global Regulation Tomorrow, July 21, 2023
- Co-author, “President Biden seeks expansion of power to punish executives of failed banks,” Norton Rose Fulbright Legal Update, March 2023
- Co-author, "Rare US FCPA advisory opinion sheds light on duress payments," Norton Rose Fulbright Legal Update, February 11, 2022
- Co-author, "Cross-border implications of the new US Strategy on countering corruption," Norton Rose Fulbright Legal Update, December 16, 2021
- Co-author, "Deputy Associate Attorney General Stephen Cox Addresses DOJ's False Claims Act Enforcement Priorities and Regulatory Reforms," Norton Rose Fulbright Health Law Pulse, February 19, 2020
- Co-author, "DOJ recovers more than $2.6 billion from health care False Claims Act cases in FY 2019," Norton Rose Fulbright Health Law Pulse, January 21, 2020
- Co-author, "Non-US citizen convicted of violating the Foreign Corrupt Practices Act despite no practical ties to US," Norton Rose Fulbright Legal Update, January 2020
- Co-author, "DOJ provides additional insight on compliance and investigations matters," Norton Rose Fulbright Legal Update, November 12, 2018
- Co-author, "Self-Reporting Bribery – The Ongoing Dilemma," Practical Law PLC, Vol. XXIX, No. 7, August 2018
- Co-author, "When criminal liability attaches to a busted project," Project Finance NewsWire, October 2017
- "The US SEC Settles Claims Against Hitachi for Alleged Corrupt Payments to Obtain Contracts to Build South African Power Stations," Client Alert (Republished in Pratt's Energy Law Report Vol. 16-1), October 8, 2015
- "Will the OECD's Latest Report on Turkey Bring Criminal Liability for Turkish Companies?," Client Alert, February 17, 2015
- "The US Department of Justice Raises the Stakes for Misleading Statements on Product Safety," April 3, 2014
- "Brazil Kicks Off New Year with Clean Companies Act," Client Alert, February 24, 2014
Speaking engagements
Speaking engagements
- Interviewed, “Navigating the DOJ’s New FCPA Guidance Podcast,” Currents Podcast June, 26, 2025
- Moderator, “Enforcement focus: Qui tam and government” NRF 20th Annual Health Law Symposium, Austin, TX, Jan. 26, 2024
- Panelist, “Episode 1: The early stages of an investigation,” Inside investigations: Stay one step ahead Podcast, Jan. 18, 2024
- Moderator, “Qui tam whistleblower and government enforcement trends” NRF 19th Annual Health Law Symposium, Austin, TX, Jan. 27, 2023
- Panelist, “Qui tam whistleblower and government enforcement trends” NRF Eighteenth Annual Health Law Symposium, Austin, TX, April 21, 2022
- Panelist, "Just When I Thought I'd Seen Everything: Beyond Investigations 101," NRF Sixteenth Annual Health Law Symposium, Austin, TX, January 24, 2020
- Panelist, "Regulatory Investigations," NRF 2nd Annual Silicon Valley International Legal Conference, Menlo Park, CA, October 3, 2019
- Panelist, "The Benefits and Risks of Self-Disclosure of Corporate Wrongdoing to the U.S. Department of Justice and the Securities Exchange Commission," NRF Webinar Series for European Businesses, May 2, 2019
- Panelist, "Top 10 Things You Wish You had Known Before an Investigation," NRF Fifteenth Annual Health Law Symposium, Austin, TX, Jan. 24, 2019
- Panelist, "How European Companies Can Avoid, Mitigate, and Manage US Civil and Criminal Litigation Risk," NRF Roundtable Presentation Series (Paris, Frankfurt, and Amsterdam, November 2018
- Interviewed, FCPA Flash Podcast, September 9, 2018
- Panelist, "Setting Up Your Case for Appeal," NACDL's 10th Annual Defending the White Collar Case, Washington, DC, November 7, 2014
- "Introduction to Anti-Corruption Compliance and Planning," American Business Forum in Turkey, Istanbul, Turkey, October 24, 2014
Memberships and activities
Memberships and activities
- Member, International Bar Association
- Chief, Criminal Division, US Attorney's Office for the District of Delaware, 2007-2012
- Assistant US Attorney, Criminal Division, US Attorney's Office for the District of Delaware, 1999-2005
- Law clerk, the Honorable Edward R. Becker, US Court of Appeals for the Third Circuit, 1997-1998