Ira Raphaelson

Senior Counsel, Washington, DC

Biography

Overview

Ira Raphaelson is one of a handful of lawyers who has been a senior executive and general counsel of public companies, independent director, law firm partner, Presidential appointee, career prosecutor, trial lawyer, and academic. Ira's extensive courtroom and boardroom experience in venues around the world make him a pragmatic and effective business and governance counselor, as well as strategic planner and advisor for bet-the-company litigation and market-entry. Ira adds his significant competition experience in compliance, litigation against government and private plaintiffs, and securing merger and joint purchasing approvals to the firm's globally recognized competition practice.

As General Counsel of Las Vegas Sands Corp, Ira's presence and governance enhancements were cited as mitigating factors in settlements with the Justice Department, SEC, and Nevada Gaming Commission. His work included strategic oversight of related whistleblower and shareholder derivative cases as well as unrelated efforts to expand and defend the company's industry leading brand. These efforts included working with domestic gaming and other regulators, as well as those in Macau and Singapore. In addition, Ira assisted Sands' international development efforts in Spain, Korea, and Japan.

As General Counsel of Scientific Games Corp, Ira was responsible for governance matters and regulatory compliance in more than 50 countries throughout the world, with manufacturing facilities in the US, Canada, UK, Austria, Chile, and China. He also assisted the company in its entry into China.

As general counsel at both companies, Ira also served as Secretary to the Board and part of the senior executive team with regard to international expansion and marketing. At various times, he also oversaw aviation, compliance, government relations, human resources, internal audit, and security.

Both as a general counsel and as a private practitioner, Ira had extensive experience designing and overseeing human resource policies including those involving whistleblowing and sexual harassment. As part of that work, he conducted dozens of internal investigations – a topic about which he serves as a frequent lecturer at legal continuing education conferences and law schools.

As an international law firm partner, he co-chaired his prior firm's white collar practice and advised numerous multi-national companies on Foreign Corrupt Practices Act (FCPA), anti-money laundering (AML), False Claims Act (FCA), sanctions, and competition issues, as well as defending individual senior government officials and corporate executives. A nationally recognized authority and lecturer on the FCPA, he conducted numerous investigations and negotiated resolutions for clients around the world. Ira represented clients in some of the largest health care cases and in the accounting cases leading up to the adoption of the Sarbanes-Oxley law. He has advised some of the world's largest financial institutions on market entry and anti-money laundering compliance serving as part of the team that secured PRC and US government approvals for the entry of the first US investment bank into China. Ira also tried eight RICO matters to juries, including two as a private practitioner.

Among other matters in competition law, Ira successfully argued for the dissolution of the New England Dairy (Agri-Mark) consent decree over the objections of the Department of Justice (DOJ) and secured DOJ approval of a joint purchasing agreement between nuclear power plant competitors. As a general counsel, he worked with White & Case teams in the successful acquisition of a competitor in a 4-3 consolidation, acquisition in UK as part of a consolidation, and the successful defense of the Italian lottery contract award in the Italian courts and ECJ.

As a career prosecutor, Ira tried numerous high-profile fraud and corruption matters and also served as US Attorney for nine months in Chicago. He was eventually tapped by President George H.W. Bush and confirmed by the US Senate to supervise all financial institution criminal and civil matters for the Justice Department as Special Counsel for Financial Institutions, where he also served as Counsel to Attorney General William P. Barr from 1991-93. As Special Counsel for Financial Institutions, he personally represented the US Government in court to obtain a US$1.2 billion forfeiture against BCCI, which was used, in part, to prevent the collapse of First American Bank.

In addition to his role as Senior Counsel, Ira also serves as lead independent director of NASDAQ-listed Inspired Entertainment and as adjunct professor of law at Northwestern University's Pritzker School of Law, where he teaches a graduate law course on all legal aspects of businesses entering foreign markets (e.g., competition, anti-corruption, sanctions, privacy, IP, corporate structure and governance, cybersecurity, tax, labor, corporate finance, repatriation, and real estate).

Bars and Courts
New York State Bar
District of Columbia Bar
Illinois State Bar
US Supreme Court
US Court of Appeals for the Fourth Circuit
US Court of Appeals for the Seventh Circuit
US District Court for the Central District of Illinois
US District Court for the Northern District of Illinois
US Court of Appeals for the District of Columbia Circuit
Education
BA
Northwestern University
JD
Northwestern University
Languages
English

Experience

Speaking Engagements

Panelist, 6th Annual Government Enforcement Institute on "The Company in Crisis: Talking to Investors, Regulators and the Media" September 12-13, 2019

Panelist, ACI's 21st New York Conference on the Foreign Corrupt Practices Act, March 15, 2019

Moderator on public relations strategies in high-profile investigations, ABA White Collar Institute, March 2019 (upcoming in New Orleans Louisiana)

Panelist on Internal Investigations, PLI Institute, April 2019 (upcoming in Chicago, Illinois)

Moderator, panel on multi-jurisdictional investigations, ABA White Collar Institute, March 1, 2018

Speaker, University of Illinois Law & Governance Conference on FCPA at 40, February 21, 2018

Panelist on Compliance, Duff & Phelps CLO/CCO In-service, November 2017

Panelist on Compliance, University of Texas Law School Governance Series, October 2017

Panelist on Internal Investigations, PLI Institute, May 2017

Panelist on FCPA Developments, ABA White Collar Institute, March 9, 2017

Panelist on General Counsel Panel, ABA White Collar Institute, March 8, 2017

Panelist on View from GC Chair, ABA Homeland Security Conference, August 2016

Panelist on How to Speak to Boards of Directors, American Conference Institute, May 2016

Panelist on Internal Investigations, PLI Institute, May 2016

Panelist on FCPA Developments, ABA White Collar Institute, March 2016

Publications

"Press...Press…Pull – When 'No Comment' No Longer Serves the Client's Interest," ABA White Collar Institute 2019

"My 'Theory of Everything'- The Evolution of Corporate Governance in the 40 years Since Passage of the Foreign Corrupt Practices Act," Illinois Law Review, forthcoming, 2019

"The General Counsel & Independent Auditor: A Critical Relationship - Can We Talk?" University of Texas Law School 4th Corporate Government Enforcement Institute, October 2017

"Two Views of Inside and Outside Counsel on FCPA and White-Collar Criminal Practice" with Tarun, ABA White Collar Institute, March 2017

"Paying For Lawyers - Some Issues for General Counsels," ABA White Collar Institute, March 2017 and PLI Chicago, May 2017

"The Road Not Taken – Some Observations on Ethical Dilemmas in Internal Investigations," ABA White Collar Institute, March 2016 and PLI Chicago, May 2016

Awards and Recognition

Martindale AV Rated (Peer & Judicial)

Northwestern University Pritzker School of Law Dean's Advisory Board (2004-Present), Chair (2014-2016), Member of Executive Committee (2006-2018)