Cheryl Scarboro is a partner in the Washington, D.C. office of Simpson Thacher & Bartlett LLP and a member of the Firm’s Government and Internal Investigations Practice. Ms. Scarboro represents corporations, financial institutions and individuals in SEC and other regulatory enforcement proceedings. She conducts internal investigations on behalf of management and boards of directors and counsels clients on Foreign Corrupt Practices Act (“FCPA”) compliance programs, SEC reporting, disclosure and corporate governance requirements.
Ms. Scarboro joined the Firm following a 19-year tenure at the Securities and Exchange Commission, most recently as the first Chief of the SEC’s FCPA Unit in the Division of Enforcement. While at the SEC, Ms. Scarboro led significant investigations involving a broad variety of subjects, including alleged violations of the FCPA, the Investment Advisers Act, issuer accounting fraud and other disclosure violations, market manipulation, broker-dealer misconduct and insider trading.
As head of the SEC’s FCPA practice, Ms. Scarboro played a role in all of the SEC’s recent major FCPA cases and acted as the SEC liaison with the Department of Justice (DOJ) and regulators around the world. In particular, Ms. Scarboro led the SEC’s investigation of Siemens, A.G., which resulted in an unprecedented $1.6 billion settlement with the SEC, DOJ and German regulators, the largest settlement to date under the FCPA. She also led investigations that resulted in actions against 15 companies and three individuals charged with making illicit payments to the Iraqi government in order to win contracts under the United Nation’s Oil-for-Food Program. In a recent FCPA investigation of a Luxembourg-based global steel pipe supplier and manufacturer, Ms. Scarboro pioneered the SEC’s first use of a deferred prosecution agreement as a means of resolving the investigation in a manner that recognized the entity’s cooperation.
Ms. Scarboro held numerous other roles while at the SEC, including serving as an Associate Director in the Division of Enforcement and as counsel to former SEC Chairman Arthur Levitt. In addition to FCPA matters, Ms. Scarboro was responsible for a number of significant financial fraud cases, including the SEC’s recent action involving Satyam Computer Services Limited, and several major insider trading cases, including the SEC’s recent action against a hedge fund manager alleged to have orchestrated a $30 million insider trading scheme.
She earned her J.D. from Duke University School of Law in 1989 and her B.A. from University of Alabama in Huntsville in 1986.