Preston L. Pugh

Partner

Partner

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Areas of Focus

Overview
Representative Matters
Recognition
Insights
Related Practices/Industries

Overview

Preston Pugh focuses on internal investigations, government enforcement defense, and False Claims Act litigation. He advises boards, special committees, and general counsel on matters involving whistleblower complaints, federal agency investigations, and allegations of executive misconduct.

He has led more than 100 internal investigations, served as lead trial counsel in multiple civil cases, and argued before more than half of the U.S. Courts of Appeals. He is currently co-leading the defense in one of the largest False Claims Act qui tam litigations in the country.

Before entering private practice, Preston served as an Assistant U.S. Attorney in the Northern District of Illinois (1999–2002), where he investigated and tried complex federal cases. He also worked in the appellate branch of the National Labor Relations Board (1997–1999) and subsequently led global compliance investigations and commercial litigation at GE Healthcare, a Fortune 10 business unit.

He has received multiple federal appointments as a compliance monitor in complex employment matters. In connection with one monitorship, the U.S. District Court in Chicago noted he came in as an outside figure "not easy to do, but he did it well." The Department of Justice consulted him as a member of the defense bar in connection with the Monaco Memo in 2022 and the creation of its first Corporate Whistleblower Awards Program in 2024.

He has conducted investigations across the United States, South America, Eastern and Western Europe, and Asia, including India, China, and Korea.  He has investigated cases in health care, financial services, defense and government contracting, manufacturing, insurance, technology, and higher education.

Career & Education

New York University School of Law, J.D., 1997
Cornell University, B.A., 1994
- New York University School of Law, J.D., 1997
- Cornell University, B.A., 1994
District of Columbia
Illinois
New York
Supreme Court of the United States
U.S. District Court for the Northern District of Illinois
U.S. Court of Appeals for the Sixth Circuit
U.S. Court of Appeals for the Seventh Circuit
- District of Columbia
- Illinois
- New York
- Supreme Court of the United States
- U.S. District Court for the Northern District of Illinois
- U.S. Court of Appeals for the Sixth Circuit
- U.S. Court of Appeals for the Seventh Circuit
Professional Activities and Memberships

Preston serves on the boards of the NYU Program on Corporate Compliance and Enforcement, the American Bar Association's Criminal Justice Section Council, the National Legal Aid & Defender Association, and JusticeAid. He also serves as a liaison between the ABA Criminal Justice Section and the Department of Justice.

Co-Chair, Global Anti-Corruption Committee, American Bar Association

Co-Chair, Qui Tam Subcommittee, ABA Criminal Justice Section

Member, ABA Task Force on Corporate Monitors

Member, National Association of Corporate Directors

Member, Society for Corporate Governance

Leadership Greater Chicago, Class of 2012

Former Member, Character and Fitness Committee, Illinois Attorney Registration and Disciplinary Commission

Former Chair, Labor and Employment Committee, Chicago Bar Association
Professional Activities and Memberships

Preston serves on the boards of the NYU Program on Corporate Compliance and Enforcement, the American Bar Association's Criminal Justice Section Council, the National Legal Aid & Defender Association, and JusticeAid. He also serves as a liaison between the ABA Criminal Justice Section and the Department of Justice.
- Co-Chair, Global Anti-Corruption Committee, American Bar Association
- Co-Chair, Qui Tam Subcommittee, ABA Criminal Justice Section
- Member, ABA Task Force on Corporate Monitors
- Member, National Association of Corporate Directors
- Member, Society for Corporate Governance
- Leadership Greater Chicago, Class of 2012
- Former Member, Character and Fitness Committee, Illinois Attorney Registration and Disciplinary Commission
- Former Chair, Labor and Employment Committee, Chicago Bar Association

Reflecting on Preston’s role in a landmark compliance monitorship, Preston was described as ‘that outsider coming in … not easy to do, but he did it well.’

— U.S. District Court in Chicago

Preston's Insights

Speaking Engagement | March 2025

"ABA National Institute on White Collar Crime," False Claims Act panel

Speaking Engagement | February 2025
Federal Bar Association Qui Tam Section Annual Program
Event
ABA White Collar Crime Conference 2024
Speaking Engagement | May 2024
"ABA International Law Section," Global Compliance Programs

View All Insights

Representative Matters

Government Investigations

Represented a Division I university following a 54-agent dawn raid involving False Claims Act and criminal false statement allegations. DOJ closed the matter with no charges filed.

Persuaded HHS-OIG to decline overbilling claims of more than $22 million against a health care joint venture.

Represented a Big Ten university in a House Select Committee on the CCP investigation; the Committee's public report reflected favorable findings.

Defended a contractor in a Senate Intelligence Committee investigation.

Represented one of the largest hospitals in the country following an on-site homicide, leading the internal investigation and advising on communications; an extensive OSHA investigation concluded with no adverse findings.

Successfully defended a health care provider in a ten-month OSHA whistleblower investigation.

Board-Level and Executive Investigations

Investigated whistleblower allegations of ethical misconduct against the CEO and CHRO of a Fortune 100 financial services company; reported findings to the audit committee and general counsel.

Investigated accounting fraud allegations at the U.S. subsidiary of a large publicly traded Japanese company; reported findings to the external auditor, leading to corrective action involving the subsidiary's CFO and CEO.

Led enterprise-wide risk assessments covering anti-corruption, trade controls, government contracts, and whistleblower channels for boards of publicly traded companies across EMEA, the U.S., and Asia Pacific.

Investigated bribery, kickback, discrimination, and misconduct allegations against the CIO of a NASDAQ-traded company following a whistleblower complaint by a former VP in India.

Led a privileged investigation of bribery, harassment, and self-dealing allegations against the CEO and general counsel of the Romanian subsidiary of a Fortune 150 financial services company.

Investigated alleged misconduct by the chief actuary of a publicly traded financial services company.

Investigated code-of-conduct complaints against a large hospital CEO.

Led an independent investigation of student-athlete allegations of abuse, favoritism, and racism against coaches at a Big Ten university, and drafted the resulting public report.