Keith M. Rosen is an experienced trial and appellate advocate whose practice focuses on white collar criminal defense, internal corporate investigations, regulatory enforcement, and Foreign Corrupt Practices Act (FCPA) compliance. He has advised and defended companies (both in the US and overseas), as well as their officers and directors, on a broad range of civil, criminal, Congressional, and regulatory matters. Mr. Rosen has successfully tried numerous criminal cases to verdict, and has briefed and argued many appeals.
Prior to joining Chadbourne, Mr. Rosen spent over ten years conducting investigations, litigating, and supervising federal criminal cases with the United States Department of Justice. From 1999-2005, Mr. Rosen was an Assistant United States Attorney, and from 2007-2012, he was the Chief of the Criminal Division for the United States 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 United States Court of Appeals for the Third Circuit.
As a prosecutor and defense counsel, Mr. Rosen has handled cases involving financial institution fraud, securities fraud, insider trading, public corruption, export enforcement, tax fraud and economic espionage. He has also litigated complex issues involving classified information under the Classified Information Procedures Act (CIPA).
Anti-Corruption Compliance and Investigations
- Represented US aerospace company in connection with criminal FCPA investigation. Case was declined by the U.S. DOJ with no charges being brought.
- Represented chairman of Japanese company in connection with FCPA investigation and parallel civil and regulatory investigations.
- Prepared anti-corruption compliance program for Turkish energy company.
- Advised Turkish holding company on anti-corruption and corporate governance issues and prepared an anti-corruption compliance program.
- Advising US private equity firm on anti-corruption issues in connection with investments in South America.
- Advised global energy company on anti-corruption due diligence issues in connection with assets in Africa.
US Export Control Compliance
- Advised South American consumer products company on US Cuba sanctions issues.
- Advised European manufacturing company on US Iran sanctions issues.
White Collar Criminal Defense and Regulatory Investigations
- Represented Star Scientific, Inc., in connection with a federal grand jury investigation that resulted in the prosecution of Virginia Governor Robert McDonnell. No charges were brought against Star at the conclusion of the investigation.
- Represented employees of Japanese auto parts manufacturers in connection with criminal antitrust investigations.
- Represented Peruvian corporation in connection with civil asset forfeiture complaint. All seized funds were returned to the client by the U.S. DOJ at the conclusion of the case.
- Represented CFO of US company investigated by the DOJ for alleged civil False Claims Act and FIRREA violations. No charges were brought against the client at the end of the investigation.
- Represented multiple individuals in connection with FINRA examinations.
- Represented domestic energy company in connection with multijurisdictional securities fraud investigation concerning the sale of oil and gas prospects.
- Represented individual defendant charged with federal tax evasion and fraud offenses.
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 were eventually dropped before trial.
- Represented intelligence agency employee in connection with internal inquiry.
- 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.
Mr. Rosen’s work as an Assistant United States Attorney included the following:
- Prosecuted one of the early cases under the Economic Espionage Act, involving theft of proprietary pricing trade secret information.
- Conducted securities fraud investigation involving manipulation of the over-the-counter stock market.
- Investigated and prosecuted insider trading case against network security manager of major corporate law firm.
- Prosecuted multimillion dollar fraud case involving small-business credit operations of major US financial institution.
- Prosecuted fraud case involving syndicated loan operations of major US financial institution.
- Conducted public corruption investigation and trial of president of municipal services organization.
Activities and affiliations
- Member, International Bar Association
Chief, Criminal Division, United States Attorney’s Office for the District of Delaware, 2007-2012
Assistant United States Attorney, Criminal Division, United States Attorney’s Office for the District of Delaware, 1999-2005
Law clerk to the Honorable Edward R. Becker, United States Court of Appeals for the Third Circuit, 1997-1998