John P. Cunningham

With over 25 years of extensive enforcement and defense experience, John Cunningham concentrates his practice on internal and government investigations, corporate compliance, and white collar matters. He advises clients on a broad range of criminal, regulatory, and compliance concerns, focusing on the FCPA and global corruption, money laundering, fraud, embezzlement, M&A and third-party diligence, sanctions, digital currency, cannabis law, and asset forfeiture. He represents companies before the DOJ, FBI, SEC, FinCEN, OFAC, CBP, and other agencies. 

He is widely recognized for his work designing, developing, enhancing, and defending corporate compliance programs in accord with evolving U.S. and global agency expectations and standards. 

Prior to joining Dickinson Wright, John served as Associate General Counsel and Americas Chief Compliance Officer for a Global 500 company and was a partner for 15 years at two elite firms. He also has deep federal enforcement experience, having served ten years as a senior trial attorney with the DOJ and investigator for the criminal division of the FBI. Additionally, he was a federal law clerk to the Honorable Gerald B. Lee in the Eastern District of Virginia.

At the core of John’s uniquely diverse practice is a keen strategic emphasis and drive to confidently provide clients across industry sectors with appropriately customized tools – from an investigations, compliance, and government enforcement perspective -- to deter, detect, prevent, and resolve issues proactively, while attentively guiding them through each step of the process.
 

Education & Credentials

Education

University of Richmond School of Law

J.D.
  • cum laude
  • Editor-in-Chief, University of Richmond Law Review
  • Moot Court Champion
  • Faculty Award for Most Outstanding Graduate

The George Washington University

M.A., American Legal History
  • summa cum laude
  • Dean’s Honor Scholar

The College of William and Mary

B.A., International Relations

Bar Admission

  • District of Columbia
  • Virginia

Acknowledgements

  • Virginia State Bar, Access to Justice Commission, Pro Bono Service Honor Roll, 2022, 2023
  • NYSE Global Corporate Crime Legal Trends Leader Recipient, 2017
  • Law Clerk to the Honorable Gerald B. Lee, Eastern District of Virginia

Prominent Assignments

  • Conducted and successfully resolved comprehensive anti-corruption, anti-money laundering, sanctions, fraud, forfeiture, and immigration-related internal or government investigations for multiple Fortune 500 companies across industry sectors.
  • Advocated to obtain advantageous outcome for global services firm in extensive DOJ, FBI, and SEC multi-agency investigation for alleged fraud and internal controls issues.
  • Directed and engineered board-mandated compliance evaluations and corresponding program enhancements for U.S. and multinational corporations in various industries.
  • Designed, implemented, and effectively defended U.S. and international compliance programs for consulting, financial services, products, technology, hospitality, private equity, IT, engineering, retail, aerospace, life sciences, and medical device companies.
  • Performed fulsome anti-corruption, anti-money laundering, trade sanctions, fraud, and third-party risk assessments for over 50 corporations, culminating in recommended and executive-approved corporate risk mitigation measures, policies, and controls.
  • Led FCPA, anti-money laundering, sanctions, general compliance, and related pre- and post-acquisition due diligence projects for a multitude of M&A transactions, resulting in successful client mergers, acquisitions, and joint ventures.
  • Investigated and favorably resolved federal individual prosecutions for FCPA, money laundering, healthcare fraud, counterfeiting, immigration fraud, and forfeiture allegations.

Professional Involvement

  • American Bar Association (Compliance and Criminal Justice Sections)
  • Federal Bar Association
  • Association of Corporate Counsel
  • Association of Certified Anti-Money Laundering Specialists
  • Society of Corporate Compliance and Ethics

Community Involvement

  • Disabled American Veterans and Veterans of Foreign Wars, Pro Bono Advocate
  • Kamp Kappa Legal Program for DC-Area Youth, Counselor
  • After School Enrichment Matters (ASEM, Arlington, VA), Fundraising Committee
  • Lost Dog and Cat Rescue Foundation, Volunteer and Donations Team

Court Admissions

  • Supreme Court of the United States
  • U.S. Court of Appeals for the Fourth Circuit
  • U.S. District Court for the Eastern District of Virginia
  • U.S. District Court for the District of Columbia

Publications/Presentations

  • Rapidly Evolving AML Risk: Tenets of Proactive Compliance (American Bankers Association, 2022)
  • U.S. Capital Markets: Evolving SEC, CFTC, AML, IRS Regulation of Digital Assets (Dubai International Financial Centre, 2021)
  • Flexibility and Vigilance: Effectively Manage Government and Internal Investigations (Corporate Counsel, Law.com, 2020)
  • Revised DOJ Guidance Provides Meaningful Compliance Road Map (Law 360, 2020)
  • Updated DOJ-SEC FCPA Resource Guide Provides Enriched Clarity to Businesses (Law 360, 2020)
  • Five Essential Elements of Corporate Compliance: A Global Template (BM Publishing, three eds., 2011, 2015, 2018)
  • Risk Assessment in India: Challenges & Best Practices for Anti-Corruption and Anti-Money Laundering (Review of Banking & Financial Services, 2015)
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