Cheryl Scarboro, formerly an Associate Director in the SEC’s Division of Enforcement and the first Chief of the SEC’s FCPA Unit, 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. She represents corporations, financial institutions and individuals in government investigations and other regulatory enforcement proceedings. Cheryl handles sensitive internal investigations on behalf of management, boards, and special committees, and routinely counsels clients on compliance programs, SEC reporting, disclosure and corporate governance requirements.
Selected representations include:
- Representation of a former employee of a mining company in an action brought by the SEC alleging accounting violations relating to the value of a project in Africa.
- Special Litigation Committee of a Fortune 50 company in an internal investigation related to the Company’s handling of allegations of sexual harassment;
- Global telecommunications company in an SEC/DOJ inquiry regarding alleged payments to government officials in various countries;
- Various senior executives in connection with SEC/DOJ investigations into potential FCPA violations;
- Large Asian company in connection with SEC investigation of potential FCPA violations;
- Special committee of a large Chinese company in an independent review of allegations of fraud; and
- Major mining consortium in South America in connection with the design and implementation of an enhanced anti-corruption program.
She is recognized as one of the “25 Most Influential Women in Securities Law” by Law360, and is consistently listed in the “Top 250 Women in Litigation” by Benchmark Litigation where market commentators describe her “huge place in the FCPA world”; “She was the leader of the SEC in the FCPA field and brings a wealth of experience to the table.” Cheryl was also recently named to Savoy Magazine’s “2018 Most Influential Black Lawyers” list. In addition, Cheryl was named to the “Enforcement 40” by the Securities Enforcement Forum, she is consistently recommended by The Legal 500 in white collar, and was named a National and Washington, D.C. “Litigation Star” by Euromoney's Benchmark Litigation in white collar.
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.