Zack Harmon

is a partner in King & Spalding’s Washington, D.C. office and is a member of the firm’s Special Matters & Government Investigations Practice Group. Mr. Harmon’s practice focuses on white collar criminal litigation and government investigations, internal investigations for corporations and the audit committees of public companies, complex civil fraud litigation and development of compliance programs.

Mr. Harmon left King & Spalding to serve as Special Assistant U.S. Attorney in the District of Columbia and then as a prosecutor in the Tax Division of the U.S. Department of Justice. His experience in these two positions included more than 25 bench and jury trials in the District of Columbia Superior Courts as well as complex criminal jury trials in various U.S. District Courts across the country. Mr. Harmon was recognized by Attorney General Janet Reno as a Tax Division Outstanding Attorney in 2000. He was then appointed to a presidential commission to lead one of the four teams that investigated the FBI’s national security and counterintelligence programs in the wake of FBI Special Agent Robert Hanssen’s espionage. In 2001, Mr. Harmon was selected to serve as trial attorney on the Enron Task Force. Finally, during 2002-2003, Mr. Harmon served as Counsel to Deputy Attorney General Larry D. Thompson.

Since his return to King & Spalding, Mr. Harmon has defended clients in numerous investigations and enforcement proceedings involving the U.S. Department of Justice, the U.S. Congress, the U.S. Securities and Exchange Commission and other federal and state agencies. In addition, he has conducted a wide variety of internal investigations and helped clients to develop comprehensive compliance and training programs. Some of Mr. Harmon’s recent representations since rejoining the firm include:

Representing numerous international corporations—including several Fortune 50 companies—in matters involving the Foreign Corrupt Practices Act, including international investigations (in Angola, Azerbajan, Bangladesh, Brazil, Brunei, Bulgaria, Canada, China, Czech Republic, the Dominican Republic, Egypt, Germany, Greece, India, Indonesia, Italy, Kazakhstan, Malaysia, Mexico, Nigeria, Poland, Russia, Saudia Arabia, Singapore, Switzerland, Turkey, the United Arab Emirates, and the United Kingdom), DOJ and SEC disclosures, and development of FCPA compliance programs, including:

Conducting multinational FCPA investigation (in Asia, India, Bangladesh and Latin America) for major freight forwarding company and assisting company with overhaul of compliance programs as well as self-disclosure to FCPA authorities—no action was taken by authorities;

Conducting multinational FCPA investigation (in five European countries) for one of the largest global medical device companies and representing company in discussions with FCPA authorities – received declinations from both the SEC and DOJ;

Conducting multinational investigation (in Africa and Middle East) for major oilfield services company and representing company in discussions with FCPA authorities;

Conducting multinational FCPA investigation (in Brunei, Malaysia and India) for major oil field services company and advising company in decisions concerning self-disclosure;

Serving as primary outside FCPA counsel for several multinational companies, and assisting in all aspects of design implementation, and operation of companies’ FCPA compliance programs; and

Advising companies in FCPA due diligence related to significant mergers, acquisitions and divestitures.

Representing several senior partners of a Big Four accounting firm in a high-profile investigation by the U.S. Department of Justice Fraud Section and the SEC;

Defending a large U.S. corporation in a complex federal and international criminal tax investigation prosecuted by the Tax Division of the U.S. Department of Justice and the U.S. Attorney’s Office in Atlanta;

Representing a Native American tribe in investigations and proceedings by the U.S. Department of Justice and the U.S. Senate concerning the activities of Jack Abramoff;

Defending GlaxoSmithKline in a consumer fraud lawsuit brought by the New York Attorney General’s Office;

Representing an individual defendant in the then-largest international antitrust conspiracy investigation and litigation;

Representing a prominent Middle Eastern bank in an investigation by the National Security Division of the U.S. Department of Justice;

Representing an Egyptian national in a fraud investigation by the U.S. Attorney’s Office for the Southern District of New York;

Representing the managing partner of an accounting firm in a criminal tax investigation;

Defending the president of a large labor union in an investigation by the U.S. Department of Labor;

Representing drug and medical device companies in criminal and civil litigation involving the U.S. Department of Justice and various U.S. Attorney’s Offices regarding “off-label” promotion and other development, sales and marketing conduct;

Conducting a review of the FBI’s Office of Professional Responsibility;

Representing pharmaceutical supply companies in a civil action against the U.S. Drug Enforcement Administration regarding the seizure of drug product;

Representing a prominent government defense contractor in a Congressional investigation; and

Routinely serving as a panelist or as featured faculty at conferences and seminars throughout the world.

Recent Recognitions

Legal 500 recognized Mr. Harmon in the category Litigation: White Collar Criminal Defense (2014)

Super Lawyers Magazine recognized Mr. Harmon in the category Washington D.C. Super Lawyers: White Collar Criminal Defense (2013 and 2014)

Main Justice profiled Mr. Harmon in connection with its awards for Best FCPA Lawyers (2013)

Mr. Harmon received the Burton Award for Legal Achivement for distinguished legal writing (2011)

Recent Publications

“Understanding the Government’s Stated FCPA Priorities for 2014,” Metropolitan Corporate Counsel, Zachary J. Harmon and Grant Nichols (May 2, 2014)

“Preparing for an FCPA ‘Industry Sweep,’” Corporate Counsel, Zachary J. Harmon and Amelia Medina (December 13, 2013)

“Conducting an Effective FCPA Internal Investigation,” Financial Fraud Law Report, Zachary J. Harmon and Laura Greig (February 1, 2013)

“A cautionary Lesson for Any Potential FCPA Targets,” Metropolitan Corporate Counsel, Zachary J. Harmon (May 1, 2012)

“SEC Receives 334 Complaints in First Seven Weeks of Dodd-Frank Whistleblower Program, Underscoring Need for Review of Corporate Compliance Policies,” Bloomberg Law Reports, Zachary J. Harmon, Jeffrey M. Stein and Laura P. Greig (January 9, 2012)

“The Long Arm of the Foreign Corrupt Practices Act,” Metropolitan Corporate Counsel, Zachary J. Harmon and Russell G. Ryan (November 8, 2010)

“Recent Trends in FCPA Enforcement: Third-Party Agents,” Bloomberg Law Reports, Zachary Harmon and Ehren Halse (August 1, 2010)

“Confronting the New Challenges of FCPA Compliance: Recent Trends in FCPA Enforcement and Practical Guidance for Meeting These Challenges,” Inside The Minds - Foreign Corrupt Practices Act Compliance Issues (Apastore, 2010)

Before joining King & Spalding in 1996, Mr. Harmon was a judicial law clerk for the Honorable William Garwood, United States Court of Appeals for the Fifth Circuit. He also worked in the Paris office of Coudert Brothers, specializing in international arbitration matters. Mr. Harmon earned his undergraduate degree, cum laude, from Princeton University and he received his law degree from the University of Texas School of Law, where he was on the Board of Advocates and the American Journal of Criminal Law. In 2006, Mr. Harmon was inducted into the prestigious American Law Institute. He is a member of the American Health Lawyers Association. He is admitted to practice in Texas, the District of Columbia, the U.S. District Court for the District of Columbia and the United States Court of Appeals for the Fifth Circuit. He retains Secret and Top Secret security clearances until their expiration.