Bill Harrington is a seasoned trial lawyer and appellate advocate. Chambers USA describes Bill as “an extremely quick study with a great mastery of complex detail and a lot of savvy,” “very smart, capable and trustworthy,” and as a lawyer who has “great style and manner with both client and with juries.”
Bill has a broad litigation practice, with a focus on government enforcement matters. Before he joined Goodwin in 2012, Bill served as a federal prosecutor in the Southern District of New York, where he focused on corruption and fraud prosecutions. Bill also formerly served as co-chair of Goodwin’s Pro Bono Committee. He currently co-heads Goodwin’s practice groups on Financial Services Disputes & Investigations and Healthcare Government Enforcement.
Representative Matters
Bill has extensive experience in both consumer banking and investment banking investigations as well as fintech companies. These include criminal matters, False Claims Act litigations and civil matters.
Representative matters include:
- An investment bank in a DOJ investigation of a bankrupt cryptocurrency hedge fund
- Multiple former employees of a bankrupt cryptocurrency issuer and exchange in DOJ, SEC, and CFTC investigations
- An investment bank in the SEC inquiry of SPAC underwriting practices
- An asset management and financial publisher in an SEC inquiry of crypto indices
- An investment bank in a DOJ fraud investigation related to cannabis investments
- A credit repair organization and various services providers in connection with deceit and abuse advertising claims brought by the Consumer Finance Protection Bureau
- A personal loan, internet lender in litigation against multiple state AGs
- Countrywide Home Loans in winning a no liability finding in a suit brought by DOJ alleging FIRREA and False Claims Act violations from the sale of mortgage loans to Fannie Mae and Freddie Mac
- A second financial institutions in similar DOJ investigations of mortgage origination practices, one resulting in a declination by the Department of Justice
- Multiple current and former bank executives in benchmark antitrust and fraud investigations, including those related to the foreign exchange markets, US treasury bonds, LIBOR, precious metals, and ISDAFIX
- Broker-dealer executives in FSA, DOJ, and SEC trading-fee probes
- Bank executives in multiple mismarking investigations
- A former state investigator in an investigation related to a New York State anti-corruption commission
- Companies, senior executives, and hedge fund traders in insider trading investigations and prosecutions
- Symphony Communication Services, a provider of encrypted communications systems, in regulatory matters related to the use of encrypted communications
- CloudFlare, a website optimizer, in disputes with copyright holders over the scope of federal injunctive authority
- GoFundMe, a crowdfunding platform, in sanctions compliance matters
His experience in healthcare matters includes representing companies and senior executives in cases involving federal healthcare fraud, the Anti-Kickback Statute, the False Claims Act, and the Stark Act.
Representative matters include:
- Winning an acquittal at a federal criminal jury trial for the former president of Warner Chilcott, a pharmaceutical company charged with for illegal marketing
- Representing multiple former employees in a DOJ and FTC investigation of a telehealth company’s prescribing and marketing practices related to controlled substances
- Representing a board member in a DOJ investigation of a pharmaceutical company’s anti-diversion practices related to the sale of controlled substances
- Representing a sales head in an FTC investigation into the marketing of health care insurance products
- Representing multiple individuals in insider trading investigations related to trades in pharmaceutical companies
- Representing a doctor who served as a consultant to a medical device manufacturer in a DOJ kickback investigation
- Representing a doctors group in a DOJ kickback investigation related to its interest in a hospital joint venture
- Representing a hospital network in a DOJ False Claims Act Investigation related to billing for mental health services
- Representing private equity investors and their portfolio companies under investigation for their investments and oversight of healthcare companies, including an investigation of laboratory and EMR tie-ins and a medical coding and billing company
- Representing a laboratory company in a DOJ investigation of its billing and write-off practices
- Representing a provider of nursing education services in connection with a kickback case that was dismissed after motion by the DOJ supporting dismissal
- Representing pharmaceutical and durable medical equipment companies in non-public DOJ investigations of billing practices, manufacturing processes, and sales strategies
- Winning a dismissal for a durable medical equipment manufacturer in a False Claims Act suit alleging fraud in its sales distribution model
- Designed compliance materials imposing safeguards around pharmaceutical company-sponsored events for non-US doctors and hospital executives
Bill has extensive experience in foreign bribery allegations and international money laundering matters.
Representative matters include:
- A cryptocurrency stable coin issuer in a DOJ Bank Secrecy Act investigation
- A senior in-house bank lawyer in a Bank Secrecy Act DOJ investigation
- An international transportation company in an internal investigation of bribery concerns related to Mexican tax audits
- Senior executives of a South American construction company in an international accounting and bribery investigation related to Brazil’s Operation Car Wash
- A Spanish soccer club in bribery investigations
- An athletic wear company in investigations related to the FIFA-bribery cases of sponsorship and advertising agreements
- A senior human resources executive at an international bank in SEC investigations related to preferential hiring of the relatives of foreign government officials
- Consumer product companies, energy company executives, financial institutions, construction company executives, and military contractors in both corporate internal and grand jury Foreign Corrupt Practices Act investigations
- A travel company and consumer product companies in developing anti-corruption training materials, audits and policies
- His matters have included those raising allegations of corruption or money laundering in Afghanistan, Argentina, Brazil, Colombia, Costa Rica, Ecuador, Ghana, Guatemala, Indonesia, Lebanon, Kenya, Mexico, Peru, Russia, Saudi Arabia, Spain, Switzerland, and Ukraine
He represents indigent individuals as a member of the Criminal Justice Act Panel for the Southern District of New York since 2013. He served on the Second Circuit’s pro bono panel from 2014 to 2020.
Areas of Practice
Professional Experience
From 2007 through 2012, Bill served as an adjunct professor at New York University School of Law, teaching a course covering the ethical and strategic considerations in exercising federal prosecutorial authority.
Bill worked in the Criminal Division of the US Attorney’s Office for the Southern District of New York from 2006 through 2012. His prosecutions focused broadly on corruption and fraud cases. Bill also served as Criminal Health Care Fraud Coordinator, responsible for cases involving health care providers and pharmaceutical companies. His matters at the US Attorney’s Office included:
- The bribery scheme involving former New York State Senator Carl Kruger, New York State Assemblyman Anthony Seminerio, two hospital CEOs and a registered lobbyist
- The conviction of investment adviser for embezzling tens of millions of dollars in client funds and defrauding clients through speculative securities investments
- A Lebanon-based money-laundering organization that laundered tens of millions of dollars in fraud proceeds throughout the Americas, Europe and Asia
- A bank employee’s scheme to mine bank computer systems, steal customer identities and misappropriate millions of dollars in home mortgages
- The conviction of the employee of a US military contractor for accepting corrupt payments in Afghanistan
- A scheme to commit access device fraud by using stolen identities, including information obtained by “phishing” financial institution and credit reporting agency data
- The prosecution of retired Long Island Railroad workers in a widespread, billion dollar disability and health care fraud scheme
- Federal program fraud, including fraudulent billing of Medicare and Medicaid and off-label marketing
- Embezzlement from hospitals and healthcare organizations
Credentials
Education
JD1999
Yale Law School
BA1995
Yale College
Clerkships
U.S. District Court for the Southern District of New York, Honorable Sidney H. Stein
U.S. Court of Appeals for the Second Circuit, Honorable Chester J. Straub
Admissions
Bars
- New York
Courts
- U.S. Court of Appeals for the Second Circuit
- U.S. District Court for the Eastern District of New York
- U.S. District Court for the Southern District of New York
Recognition & Awards
Bill has been widely recognized as a leading lawyer, including by:
- Chambers USA for his work in White Collar Crime & Government Investigations Litigation. His clients have referred to Bill as a “brilliant trial lawyer who has a great demeanor with clients”
- The Best Lawyers in America for his work in Criminal Defense: White-Collar
- US News Best Lawyers as a top white collar lawyer
- LMG Life Sciences as a Star Individual in litigation and enforcement Super Lawyers as a top white collar lawyer
- Super Lawyers as a top white collar lawyer
- Benchmark Litigation as a Litigation Star in New York for his work in Commercial & White Collar Crime
- Euromoney’s Expert Guides: White Collar Crime Lawyers as one of the world’s leading white collar crime lawyers
- Global Investigations Review 100 as a highly regarded investigator
At Yale Law School, Bill earned the Potter Stewart Prize (Best Team) in the Morris Tyler Moot Court competition and he served as an editor of the Yale Law Journal and the Journal of Law and Humanities.
Publications
Bill frequently writes and comments on government investigations and enforcement, the False Claims Act, and other topics related to healthcare, consumer, and investment banking investigations. Recent publications include:
- Co-Author, “The False Claims Act and Kickbacks: Factual Causality Required,” New York Law Journal, April 26, 2023
- Co-Author, “Chopra’s Deputies: State Attorneys General and Consumer Protection,” New York Law Journal, June 2022
- Co-Author, “PE Investment in Health Care Attracting Greater Federal Scrutiny,” New York Law Journal, June 2021
- Co-Author, “For Civil Enforcement, The Pandemic Is Just Beginning,” New York Law Journal, April 2021
- Co-Author, “To Fight Pandemic, Health Care Companies Face New Opportunities But Old Legal Risks,” New York Law Journal, April 2020
- Co-Author, “Enforcement Risks For Recipients of U.S. CARES Act And Other Federal Funds,” Goodwin Client Alert, April 2020
- Co-Author, “New Attack on Physicians Compensation Models Under the Stark Law,” New York Law Journal, December 2019
- Co-Author, “Does Violating Medicare Regulatory Guidance Still Create False Claims Act Liability?,” New York Law Journal, June 2019
- Co-Author, “Circuit Rulings on CIDs Show Agency Deference is Not Unconditional,” New York Law Journal, September 2018
- Co-Author, “Two Recent Cases Illustrate Need to Rely on Causal Concepts in FCA Cases,” New York Law Journal, June 2018
- Co-Author, “A Simple Solution to End the Encryption Debate,” TechCrunch, May 2018
- Co-Author, “DOJ Gives Mixed Messages on False Claims Act Enforcement,” New York Law Journal, February 2018
- Co-Author, “Fraud and Abuse Enforcement Goes High Tech,” New York Law Journal, June 2017
- Co-Author, “Under Sessions-Led Justice Department, FCA Enforcement Likely to Continue Apace,” New York Law Journal, February 2017
- Co-Author, “False Claims Act Round Up: Attacking Claims Post-‘Escobar’,” New York Law Journal, November 2016
- Co-Author, “Supreme Court Limits Scope of Asset Forfeiture,” New York Law Journal, July 2016
- Co-Author, “Supreme Court to Review Theory of Implied False Claims Act Liability,” New York Law Journal, February 2016
- Co-Author, “Turning an Exacting Eye to Physician-Hospital Compensation,” New York Law Journal, November 2015
- Co-Author, “The False Claims Act and Corporate Integrity Agreements,” New York Law Journal, August 2015
- Co-Author, “Where Rules Collide: the Problem of Confidentiality and Whistleblowers,” New York Law Journal, May 2015
- Co-Author, “Collateral Consequences of Individual Liability,” New York Law Journal, February 2015
- Co-Author, “Recent Challenges to Administrative Adjudication of Fraud Claims,” New York Law Journal, December 2014
- Co-Author, “Dodd-Frank’s New Deputies of Federal Consumer Financial Laws – States,” New York Law Journal, September 2014
- Co-Author, “Civil Enforcement Actions: Whither the Fifth Amendment?” New York Law Journal, May 2014
- Co-Author, “Quality Control Breakdowns Form Basis of Government Action,” New York Law Journal, February 2014