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COLIN R. JENNINGS


PARTNER


 * Cleveland
   T +1 216 479 8420
   T +1 216 479 8420

colin.jennings@squirepb.com View Full Bio

Colin R. Jennings serves as primary outside counsel for global compliance for
more than 35 public and privately held global companies. He regularly provides
guidance and counseling in connection with his clients’ ongoing compliance
efforts related to their domestic and international operations, including, when
necessary, investigation and defense of compliance-related concerns.

A significant portion of Colin’s practice focuses on conducting independent
reviews of compliance programs, including the evaluation of each program’s
structure, operation and performance. He regularly conducts compliance reviews
and internal investigations throughout the US and globally. His advice on the
design, implementation and assessment of compliance programs is informed by
extensive experience not only handling investigations, but also in litigating
claims arising from compliance-related matters. Colin regularly presents on
global compliance programs, and is the author of numerous articles and chapters
on the topic.

Colin has successfully tried numerous civil and criminal matters in various
federal and state courts. His active litigation practice focuses on complex
civil and criminal matters, including responses to governmental investigations
and enforcement actions. As a natural extension of his compliance and litigation
practice, Colin has an active data privacy and breach response practice. He
regularly interacts with federal, state and international authorities concerning
data breaches, and coordinates the forensic analysis, crisis communications and
claims or litigation that inevitably follow a breach.

Colin’s criminal practice involves representing public and private corporations
and business professionals in response to criminal or regulatory investigations.
Throughout the US and globally, he conducts internal investigations into
allegations of employee misconduct, fraud or other business crimes, including
the Foreign Corrupt Practices Act (FCPA), False Claims Act, Economic Espionage
Act, OFAC sanctions, money laundering and a variety of cybercrimes.

In addition, Colin has diverse and extensive experience in complex civil
litigation arising from matters of fraud, abuse and criminal misconduct. This
work includes the regular representation of professional athletes and other
high-net-worth individuals who are the victims of fraud and violations of trust.
Colin has represented athletes in all major sports leagues, including the NFL,
NBA, MLB, NHL, PGA and LPGA.

Read More
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EXPLORE

   
 * Experience
   
 * Credentials
   
 * Recognitions
   
 * Insights & Events
   
 * News
   
 * Blogs
   
 * Publications & Speaking Engagements
   

ExperienceCredentialsRecognitionsInsights & EventsNewsBlogsPublications &
Speaking Engagements Select
ExperienceCredentialsRecognitionsInsights & EventsNewsBlogsPublications &
Speaking Engagements

Investigations/White Collar Defense/Compliance

 * Conducting an internal investigation regarding large-scale falsification of
   laboratory data and certifications of a global company, and related
   coordination, analysis and handling of customer, regulatory and damages
   claims.
 * Conducting internal investigations and defense of matters related to
   potential violations of the Office of Foreign Assets Control (OFAC) sanctions
   for numerous companies in the Middle East.
 * Conducting an independent review of the global compliance program of a
   Fortune 100 company, and presentation to the board on the operation and
   effectiveness of the program.
 * Special counsel to the state of New Jersey on federal gambling laws related
   to reorganization of the state lottery system.
 * Defending a Foreign Corrupt Practices Act prosecution arising from an oil
   pipeline project.
 * Defending healthcare fraud prosecutions related to alleged kickbacks, billing
   misconduct and questions regarding medical necessity.
 * Assisting a large multinational oil company in connection with its compliance
   with the USA Patriot Act as a result of its fleet and credit card operations.
 * Advising a publicly traded company on its anti-money laundering compliance
   program related to its precious metals business. This effort included an
   overall review and implementation of the program and will include related
   training, including Know Your Customer due diligence requirements and AML
   risk assessments.
 * Conducting internal investigations and defense of matters related to
   potential violations of the FCPA for numerous companies involving various
   countries, including Mexico, Russia, China and India.
 * Conducting internal investigations related to suspected misappropriation of
   trade secrets and embezzlement by employees for numerous clients.
 * Defending False Claim Act/qui tam matters alleging wide-scale fraud in
   connection with large low-cost housing projects.
 * Defending Economic Espionage Act prosecutions and parallel civil litigation.
 * Representation of a large publicly traded company in connection with a data
   breach in Europe and Asia arising from the hacking of employee email
   accounts, including coordination of the forensic review, assessment of cost
   recovery, asset recovery in the European Union, and efforts to close
   fictitious bank accounts and domains in various jurisdictions.
 * Coordinating the breach response of a large publicly traded company,
   including analysis of breach notification obligations for all 50 states.
 * Coordinating the breach response for a large publicly traded company
   resulting from the cyberattack on its consumer-facing websites.
 * Conducting internal investigations for various public entities arising from
   claims of public corruption or embezzlement, and coordinating cooperation
   with law enforcement and related insurance and other recovery actions.
 * Defending large healthcare fraud investigations for publicly traded
   healthcare companies.
 * Defending mortgage fraud investigations and prosecutions in both state and
   federal court.
 * Conducting an internal investigation and defense of a leading environmental
   services company related to claims of falsification of landfill monitoring
   data.
 * Defending company executives in criminal antitrust investigations into price
   fixing in the automotive industry, and defense of related civil discovery.
 * Defending companies, public sector entities and individuals in numerous grand
   jury, OIG and other similar investigations and administrative enforcement
   actions. 
 * Defending large metropolitan school districts in connection with statewide
   data manipulation investigation by the State Auditor and Department of
   Education.

Complex Civil Litigation

 * Defending a leading aerospace company against claims of fraud and breach of
   contract resulting from alleged export law violations.
 * Prosecution of claims on behalf of an international telecommunications
   company arising from the cybersecurity breach and theft of trade secrets.
 * Successfully rescinded a stock purchase agreement related to the acquisition
   of a company that was the subject of a state and federal money laundering
   investigation.
 * Representing a large multinational insurance company in the defense of claims
   of antitrust and bid rigging.
 * Defending several large insurance companies in national class actions
   asserting claims arising from credit insurance markets, and defending claims
   of breach of contract and bad faith against various insurers.
 * Defending a leading international supplier of pollution control systems for
   power generation plants against claims of breach of contract.
 * Defending criminal investigation and related litigation arising from the
   collapse of a large Ponzi scheme based upon mortgage-backed securities.
 * Prevailing at trial and obtaining a full recovery from the state of
   California in an action arising from the refusal to reimburse a large
   healthcare provider for its responses to 911 emergency calls.
 * Defending a publicly traded real estate development company in a dispute
   related to a large-scale mixed-use development in Miami; trial resulted in a
   favorable verdict for the client.
 * Prevailing at trial on claims related to theft and embezzlement by a
   financial services provider.
 * Representing PGA, LPGA, MLB, NBA, NHL and NFL players in connection with
   actions arising from mismanagement of their assets, investments and finances,
   and other related representations.

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EDUCATION

 * Case Western Reserve University, J.D., 1997
 * Allegheny College, B.A., 1994


ADMISSIONS

 * Ohio, 1997


COURTS

 * U.S. Ct. of App., Sixth Circuit
 * U.S. Dist. Ct., S. Dist. of Ohio
 * U.S. Dist. Ct., N. Dist. of Ohio


MEMBERSHIPS & AFFILIATIONS

 * Law360 Compliance Editorial Advisory Board
 * John M. Manos Inn of Court
 * Cleveland Metropolitan Bar Association
 * Former chair of the Certified Grievance Committee and served as trial counsel
   for the CMBA in various lawyer discipline matters
 * Former chair and a member of the leadership team for the Criminal Law Section

Next:
 * Named Thomson Reuters Stand-out Lawyer in 2023
 * “Cleveland-based partner Colin Jennings is representing an automotive
   manufacturer in an ongoing matter before attorney general offices in all 50
   US states and the Canadian data regulator in relation to a data breach that
   affected customer records of 3.3 million individuals. He also advises dozens
   of other clients on compliance, regulatory investigations and private
   litigation, as well as data breach response” -– Global Data Review 100 2023
 * Recognized Practitioner in Chambers USA for Litigation – White-Collar Crime &
   Government Investigations in Ohio 2023. Chambers states he is well regarded
   for his white-collar criminal defense practice, which includes advising
   companies on compliance issues, as well as representing clients in government
   investigations. “He is a top strategic thinker with excellent research
   skills.”
 * Recognized Practitioner in Chambers USA for Litigation – White-Collar Crime &
   Government Investigations in Ohio 2022. Chambers states he is well regarded
   for his white-collar criminal defense practice, which includes advising
   companies on compliance issues as well as representing clients in government
   investigations. “He's smart, a good writer and a hard worker.”
 * “He is very experienced in internal investigations and crisis managements,
   and he's our go-to person in those situations. He is a very practically
   minded lawyer.” – Client Feedback, Acritas Stars Database
 * Well regarded for his white-collar criminal defense practice, which includes
   advising companies on compliance issues, as well as representing clients in
   government investigations. “He is a skilled technician when it comes to
   internal investigations.” – Chambers USA 2021
 * Recognized in Best Lawyers for Commercial Litigation
 * Listed in Ohio Super Lawyers

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Load More: BLOGS
Next:

 * Co-presenter, “Defending the Privilege of a Forensic Report,” webinar,
   Federal Bar Association, January 2023.
 * Co-author, “Reevaluating Organizations' Cybersecurity Needs After Log4j,”
   Law360, January 19, 2022.
 * Co- author, “4 Considerations In Light Of Cyber Incident Notification
   Bill,” Law360, August 9, 2021
 * Co-author, “What Private Cos. Can Learn From Biden Cybersecurity Order,”
   Law360, May 27, 2021.
 * Co-author, “Executive Responsibilities and Consequences: A Case Study of
   Uber’s Data Breaches,” Corporate Compliance Insights, September 1, 2020.
 * Co-author, “COVID-19, the CARES Act and the need for robust compliance,”
   Financier Worldwide, July 2020.
 * Co-author, “Cyber Breach Forensic Reports: Is Your Report Discoverable?”
   Legaltech News, December 17, 2019.
 * Speaker, “Hot Topics in Corporate Compliance,” Biennial White Collar Crime
   Institute, November 2018.
 * Co-author, “CMS Proposes Invalidating Adjuster Methodology and Recouping Past
   Improper Payments From Medicare Advantage Organizations,” Squire Patton Boggs
   Client Alert, November 2018.
 * Co-author, “Challenging the DOJ’s Accomplice Liability Strategy for Reaching
   Foreign Conduct in International Bribery Schemes,” PLI Current: White Collar
   Practice Journal, November 2018.
 * Co-author, “CMS Proposes Invalidating Adjuster Methodology and Recouping Past
   Improper Payments From Medicare Advantage Organizations,” Squire Patton Boggs
   Anticorruption Blog, November 15, 2018.
 * Speaker, “Global Compliance Forum: Minimizing Risk to Protect Your Business
   Interests,” Squire Patton Boggs Client Event, October 19, 2018.
 * Speaker, “Global Issues Forum: Global Compliance – Best Practices,”
   Association of Corporate Counsel’s National Capital Region, September 6,
   2018.
 * Co-author, “Circuit Rejects Expansive Use of Conspiracy for FCPA,” Squire
   Patton Boggs Anticorruption Blog, August 26, 2018.
 * Co-author, “DOJ Announces Revised FCPA Corporate Enforcement Policy,” Squire
   Patton Boggs Anticorruption Blog, January 25, 2018.
 * Speaker, “Global Compliance Forum: Minimizing Risk to Protect Your Business
   Interests,” Squire Patton Boggs Client Event, November 1, 2017.
 * Speaker, “Are you ready for a Crisis? Corporate Governance in the Context of
   Crisis Management,” Ohio Chapter Meeting of the Society for Corporate
   Governance, April 6, 2017.
 * Speaker, “White Collar Crime in America and the World: Preventing, Detecting
   & Remediating Wrongful Conduct,” CMBA’s Biennial Institute on White Collar
   Crime, December 9, 2016.
 * Speaker, “Ethics in a Corporate and Business Setting,” Case Western Reserve
   Law and Business Fall 2016, November 9, 2016.
 * Co-author, “All the Injury Required? How the Supreme Court’s Spokeo Decision
   May Alter the Road for Privacy Litigants,” Squire Patton Boggs Client Alert,
   September 2016.
 * Speaker, “2016 US Roundtable for General Counsel in the Chemical and
   Performance Materials Industry,” Squire Patton Boggs Client Alert, April
   2016.
 * Speaker, “Best Practices for Internal Investigations in 2016,” Annual Fraud
   and Forensics Day, Northeast Ohio Institute of Internal Auditors and
   Association of Certified Fraud Examiners joint meeting, February 2016.



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