Preston L. Pugh

Overview

Preston Pugh is a partner in the firm’s Washington, D.C. office and serves as co-chair of the firm’s Chambers-ranked False Claims Act Practice. He represents large companies, universities, and institutions in investigations and litigation of allegations of fraud and other misconduct in federal contracts, grants, and programs. Clients also rely on him for his experience in handling board-facing complaints, crisis management, and assistance to senior management in navigating reputational risks. He has successfully tried, arbitrated, and advocated on appeal numerous federal and state cases, and has served in roles including lead outside counsel for multinational corporations and large organizations; head of global compliance investigations for a P&L of a Fortune 10 corporation; Assistant U.S. Attorney in Chicago; and an independent compliance monitor. His contributions have been acknowledged in the 2024 edition of Savoy magazine’s “Most Influential Lawyers” and in The Legal 500, among others.

Preston possesses a deep understanding of established and emerging whistleblower regulatory frameworks, both domestically and internationally. His investigations have covered a wide range of allegations, including health care and securities fraud, ethical misconduct, foreign corrupt practices, money laundering, violations of anti-kickback laws, OSHA violations, product safety violations, toxic workplace issues, and insider trading. He was recently consulted by the Department of Justice (DOJ) regarding the launch of its new Corporate Whistleblower Awards Pilot Program in August 2024, as well as on the “Further Revisions to Corporate Criminal Enforcement Policies” memo, known as the September 2022 “Monaco Memo.” He also has extensive jury trial experience in this area.

Preston currently serves as one of the two liaisons between the ABA Criminal Justice Section and the DOJ; a member of the board of the NYU Program on Corporate Compliance and Enforcement, a preeminent corporate compliance think tank; a member of the steering committee for the Federal Bar Association Qui Tam Section; and a member of the board of the National Legal Aid and Defender Association. He was recently the lead author in the first-ever chapter on the False Claims Act in the Global Investigations Review’s The Guide to Compliance and is published extensively on investigations and crisis management. He also serves as the moderator of the False Claims Act panel at the ABA National Institute on White Collar Crime. In addition, Preston is part of a small group that has worked with senior DOJ leaders from around the country to create the first Charlotte E. Ray lecture at Howard University School of Law.

Career & Education

Department of Justice: United States Attorneys' Office
Northern District of Illinois: Assistant U.S. Attorney, 1999–2002
National Labor Relations Board
Appellate Court Branch, 1997–1999
- Department of Justice: United States Attorneys' Office
  Northern District of Illinois: Assistant U.S. Attorney, 1999–2002
- National Labor Relations Board
  Appellate Court Branch, 1997–1999
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

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

Co-Chair, Qui Tam Subcommittee, Criminal Justice Section, American Bar Association

American Bar Association's Task Force on Corporate Monitors

Leadership Greater Chicago, Class of 2012

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

Former Chair, Labor and Employment Committee, Chicago Bar Association
Professional Activities and Memberships
- Co-Chair, Global Anti-Corruption Committee, American Bar Association
- Co-Chair, Qui Tam Subcommittee, Criminal Justice Section, American Bar Association
- American Bar Association's Task Force on Corporate Monitors
- Leadership Greater Chicago, Class of 2012
- Former Member, Character and Fitness Committee, Illinois Attorney Registration and Disciplinary Committee
- 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

Defending a large integrated health care provider in a DOJ False Claims Act investigation in connection with the provider’s submission of multiple years of state-approved ACA rate increases.
Defending a DoD government contractor in a DOJ False Claims Act investigation of several companies in cloud migration for alleged bid rigging, in violation of the False Claims Act.
Led privileged internal investigation of a whistleblower complaint regarding a Fortune 100 CEO and CHRO in the financial services industry for ethical misconduct. Included, at the company’s request, interviews of all members of the company’s executive management committee and other corporate officers. Reported successful conclusion of the investigation to audit committee and general counsel.
Led privileged internal investigation of whistleblower allegations regarding the CEO and general counsel of an Eastern European subsidiary of Fortune 150 financial services company, focusing on allegations of bribery, ethical misconduct, harassment, and self-dealing that were made against the subsidiary’s GC and CEO.
For a board of directors of a publicly traded company, led a comprehensive risk assessment of the company in Europe, the Middle East, Africa, U.S., and Asia Pacific covering anti-corruption, third-party due diligence, cartels, government contracts, trade controls, and the use, availability, and structure of its whistleblower reporting channels.
Successfully defended a large convention and sports authority in a grand jury investigation by the DOJ, focusing on allegations of conflicts and bid rigging by the authority’s CEO.
Successfully defended government contractor in arbitration filed by several employees who were terminated at the conclusion of a DOJ investigation for alleged falsification of time cards.
Successfully defended a large health care provider joint venture, facing claims by HHS-OIG of overbilling by more than $22 million. After considerable discussions with OIG, the government reversed its decision and decided against pressing any claims.
Led investigation of whistleblower allegations for product safety noncompliance and failure to provide accurate testing reports to the company’s outside certifying body.
Led the successful defense of a large health care provider in a ten-month OSHA whistleblower investigation regarding allegations of noncompliance with OSHA safety reporting standards and the provision of N95 masks.
Investigated whistleblower allegations regarding accounting fraud by a U.S. subsidiary of a large publicly traded Japanese company, reporting results to external auditor. Investigation resulted in corrective action for subsidiary’s CFO and CEO.
Conducted a nine-month internal investigation of a health care medical device company regarding allegations of kickbacks, off-label marketing, and other health care compliance issues.
Represented one of the largest hospitals in the United States after the on-site homicide of a nurse-practitioner. Led a team to conduct an internal investigation of the homicide and hospital security protocols. Advised the hospital regarding communications and discussions with internal and external stakeholders. Represented the hospital in associated extensive OSHA investigation, which resulted in no adverse findings against the hospital.
Jointly led the internal investigation of an airline in an industry-wide False Claims Act and false statements investigation by the DOJ and the U.S. Postal Service. The investigation was both domestic and global, took place over several years, and involved dozens of witnesses.
Defended FCA and criminal false statement allegations against a Division I university following a well-publicized 2013 dawn raid by 54 federal and state law enforcement agents. Advised university regarding crisis communications, discussions with law enforcement, internal and external stakeholders, and internal investigation of the issues. After several years, the DOJ closed the investigation with no charges filed.
Led an independent investigation of alleged conduct by coaches on a Big Ten sports team, including highly publicized allegations by student-athletes of abuse, favoritism, and racism. Drafted public report issued to all university alumni.
Retained by a board of directors to investigate numerous code of conduct complaints against the CEO of a large hospital, including conflicts of interest and other allegations.
Led internal investigation of the chief of police of a large county authority. Allegations included workplace harassment, bullying and discrimination spanning a decade. Reported to and advised executive director of the county, and also county board of director.