Keith Rosen

Head of Risk Advisory, United States Norton Rose Fulbright US LLP
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

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

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