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Internal Investigations + Corporate Compliance

Businesses, nonprofits, educational institutions, and a wide range of organizations often call on our Internal Investigations + Corporate Compliance practice group to investigate concerns of organizational, employee, and third-party misconduct.

Our clients trust us to conduct discrete, expeditious and thorough internal investigations of complex sensitive matters.  We understand the urgency when corporate compliance issues come to light.  Our team is trained to conduct efficient and cost-effective investigations with the goal of limiting potentially damaging publicity or possible regulatory or prosecutorial action. Because we service a broad array of international clients, we are frequently retained to conduct complex cross-border investigations. We help you consider the full range of appropriate remedial actions, while taking your business objectives into and the regulatory landscape into account.

Although most of our investigations are resolved before they become public, when required we mobilize our world-class trial practice that combines the substantial resources of a large firm with the depth of trial experience, efficient staffing, and responsiveness of a trial boutique.

Our Services

We conduct internal investigations in a vast range of industries, such as manufacturing, health care, financial services, education, construction, insurance, aerospace, and technology. Our investigations involve many types of allegations and issues, including:

  • Antitrust concerns
  • Consumer fraud and unlawful sales practices
  • Corporate governance
  • Corruption and Foreign Corrupt Practices Act (FCPA) violations
  • Data breaches and cybersecurity
  • Executive and employee misconduct, including embezzlement and harassment
  • Financial and accounting reporting issues
  • Health care fraud and abuse
  • Government contracting and grant fraud
  • Insider trading, market manipulation and other securities fraud
  • Misappropriation of trade secrets
  • Product safety
  • Sexual misconduct allegations
  • Tax offenses
  • Trade and export compliance
  • Workplace safety and environmental violations


We have extensive experience conducting internal investigations in the context of parallel government investigations, civil litigation, and administrative actions. We assist clients make voluntary disclosures to government agencies when appropriate, and often marshal the facts and the law to convince government agencies to decline prosecution. We have successfully negotiated favorable resolutions in disputes with the government where the amounts at issue have reached into the nine-figure range.

Our Team

Our team includes lawyers with substantial government and private sector experience, and who collaborate across our firm’s practice groups, including Business Transactions; Environmental, Energy + Telecommunications; Labor, Employment, Benefits + Immigration; and Litigation.

We collaborate with each client’s team to develop an appropriate investigation structure, timeline, and goals. We often work with our clients’ executives, general counsel, boards, and audit committees or special litigation committees.

Our strong credibility and long-standing relationships with government lawyers overseeing enforcement actions enable us to effectively advocate on behalf of our clients. In addition to conducting investigations, we apply our experience and proficiency in these matters to design and implement remedial and preventive compliance measures and enhance compliance programs.

Our top-tier Internal Investigations + Corporate Compliance practice group has an extensive understanding of the regulatory landscape in our clients’ industries. We take your business objectives into account while helping you navigate concerns of organizational, employee, and third-party misconduct.

Experience

Employee Misuse of Technology

Conducted internal investigations for manufacturing, health care, financial services, and educational organizations arising from concerns about misuse of the entities' technology by employees, including attempts to access potentially illegal or contraband content, or to misappropriate confidential, proprietary information or trade secrets. In some instances, those investigations have required coordination with law enforcement agencies to demonstrate that the client entity itself had not engaged in wrongful conduct.

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Government Investigations: Claims of Defrauding Federal Government

Represented Rhode Island construction company in connection with claims that the company was defrauding the federal government in connection with an ongoing project. After conducting an internal investigation for the company, we worked with the company to prepare a self-disclosure to the federal government demonstrating the isolated nature of the issue and the company's remedial action. In response, the federal government decided to take no action whatsoever against our client.

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Government Investigations: Alleged Fraudulent Billing

Counseled Rhode Island medical practice in connection with government investigation related to alleged fraudulent billing. As a result of our prompt and targeted internal investigation, which was conducted contemporaneously with the government's investigation, we were able to identify the source of the incorrect allegations and shared that with law enforcement, leading to the closure of the investigation of our client with no adverse action against it.

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Publications

DOJ Issues Sweeping Guidance on Unlawful Discrimination for Federal Funding Recipients teaser
September 8, 2025

DOJ Issues Sweeping Guidance on Unlawful Discrimination for Federal Funding Recipients

March 24, 2025

Here’s how commercial contracts can ease the cost burden of new tariffs impacting manufacturers

Hartford Business Journal

Commercial contracts tend to be full of “boilerplate provisions” that, to paraphrase Mark Twain’s assessment of classic novels, everyone knows are important, but no one actually reads. When COVID-19 struck, manufacturers learned all about the significance of one particular boilerplate provision — force majeure. This type of provision can excuse or postpone contractual performance in the face of a materially unforeseen event beyond the party’s control. It was a pivotal tool for countless manufacturers seeking relief from their contractual burdens because of severe operational challenges brought on by the global pandemic. This boilerplate provision may become critical again as manufacturers in the U.S. and abroad face the increasing threat of new federal tariffs. Triggering events Force majeure translates as “superior force.” Arising from the Napoleonic Code, or French Civil Code, which was established in France in 1804 and remains in amended use today, this legal concept excused a commercial party from damages liability under a contract if their nonperformance (e.g., the product was not delivered) was “by consequence of a superior force or of a fortuitous occurrence.” Force majeure provisions have been part of American commercial contracting since at least the 19th century, when the U.S. Supreme Court recognized their validity in a case called The Tornado. Like the pandemic, tariffs may present a new severe operational challenge for manufacturers that rely on imported raw materials, components or equipment. “A 25% tariff on Canada and Mexico threatens to upend the very supply chains that have made U.S. manufacturing more competitive globally,” according to Jay Simmons, the president and CEO of the National Association of Manufacturers. “The ripple effects will be severe, particularly for small and medium-sized manufacturers that lack the flexibility and capital to rapidly find alternative suppliers, or absorb skyrocketing energy costs,” he added. This begs the question: Could these new federal tariffs constitute a force majeure event that excuses, or at least delays performance under a commercial contract? The answer depends on the specific language used in the contract. A provision’s heading is generally irrelevant to the parties’ rights, so merely including the words “force majeure” in a contract is unlikely to provide relief. Facing serious supply chain problems in 2020, many manufacturers were disappointed to learn that the force majeure provisions in their contracts listed a series of triggering events, such as acts of God, natural disasters and war, but said nothing about pandemics. The COVID-19 case law was not a model of consistency when it came to whether these provisions are interpreted narrowly, but some courts have been reluctant to imply that “pandemics” were meant to be covered when they were not expressly listed in the provision. The options may be better for manufacturers this time around. Force majeure provisions often list “government action” as a triggering event, and a tariff could qualify as such an action. If tariffs are not specifically listed, however, the rule of narrow interpretation might lead to a contrary result. The outcome will depend on the applicable state law and precise contract language. Additionally, force majeure provisions sometimes include requirements that the triggering event must be unanticipated and/or make performance impossible. Lawyers might argue that tariffs were not unanticipated events, particularly for contracts drafted since January 2025, or that substantially increased costs make performance “unprofitable” or “very difficult,” but not impossible. The development of a new commercial contract, or the renewal or amendment of an existing one, presents an ideal opportunity to mitigate uncertainty around this point. Manufacturers may want to evaluate whether (or not) a contract needs a force majeure provision excusing performance because of tariffs, and insist on language that explicitly includes (or excludes) tariffs and identifies the circumstances under which they may (or may not) qualify as a triggering event. The details matter here. Read the article.

January 27, 2025

The Promise and the Peril: AI and Disruptive Technologies in Operations and Compliance

ACC Docket

The article covers the Department of Justice’s (DOJ) September 2024 revisions to the Evaluation of Corporate Compliance Programs (ECCP) that incorporate artificial intelligence (AI) management and the benefits and concerns of this technology. "The 2024 ECCP update is a lighthouse for companies navigating the uncertain waters of the rapidly evolving world of AI and disruptive technologies,” they wrote. “It warns of the perils—the rocks of malign use—and the DOJ’s focus on those perils. [I]t guides to relative safety—a harbor calmed by the breakwater of risk awareness and mitigation.” David and Kathryn emphasize that “[c]ompanies with exposure to AI and disruptive technologies” should understand the ECCP update and the implications arising from it. To read the article, click here.

DOJ Issues Sweeping Guidance on Unlawful Discrimination for Federal Funding Recipients teaser
September 8, 2025

DOJ Issues Sweeping Guidance on Unlawful Discrimination for Federal Funding Recipients

March 24, 2025

Here’s how commercial contracts can ease the cost burden of new tariffs impacting manufacturers

Hartford Business Journal

Commercial contracts tend to be full of “boilerplate provisions” that, to paraphrase Mark Twain’s assessment of classic novels, everyone knows are important, but no one actually reads. When COVID-19 struck, manufacturers learned all about the significance of one particular boilerplate provision — force majeure. This type of provision can excuse or postpone contractual performance in the face of a materially unforeseen event beyond the party’s control. It was a pivotal tool for countless manufacturers seeking relief from their contractual burdens because of severe operational challenges brought on by the global pandemic. This boilerplate provision may become critical again as manufacturers in the U.S. and abroad face the increasing threat of new federal tariffs. Triggering events Force majeure translates as “superior force.” Arising from the Napoleonic Code, or French Civil Code, which was established in France in 1804 and remains in amended use today, this legal concept excused a commercial party from damages liability under a contract if their nonperformance (e.g., the product was not delivered) was “by consequence of a superior force or of a fortuitous occurrence.” Force majeure provisions have been part of American commercial contracting since at least the 19th century, when the U.S. Supreme Court recognized their validity in a case called The Tornado. Like the pandemic, tariffs may present a new severe operational challenge for manufacturers that rely on imported raw materials, components or equipment. “A 25% tariff on Canada and Mexico threatens to upend the very supply chains that have made U.S. manufacturing more competitive globally,” according to Jay Simmons, the president and CEO of the National Association of Manufacturers. “The ripple effects will be severe, particularly for small and medium-sized manufacturers that lack the flexibility and capital to rapidly find alternative suppliers, or absorb skyrocketing energy costs,” he added. This begs the question: Could these new federal tariffs constitute a force majeure event that excuses, or at least delays performance under a commercial contract? The answer depends on the specific language used in the contract. A provision’s heading is generally irrelevant to the parties’ rights, so merely including the words “force majeure” in a contract is unlikely to provide relief. Facing serious supply chain problems in 2020, many manufacturers were disappointed to learn that the force majeure provisions in their contracts listed a series of triggering events, such as acts of God, natural disasters and war, but said nothing about pandemics. The COVID-19 case law was not a model of consistency when it came to whether these provisions are interpreted narrowly, but some courts have been reluctant to imply that “pandemics” were meant to be covered when they were not expressly listed in the provision. The options may be better for manufacturers this time around. Force majeure provisions often list “government action” as a triggering event, and a tariff could qualify as such an action. If tariffs are not specifically listed, however, the rule of narrow interpretation might lead to a contrary result. The outcome will depend on the applicable state law and precise contract language. Additionally, force majeure provisions sometimes include requirements that the triggering event must be unanticipated and/or make performance impossible. Lawyers might argue that tariffs were not unanticipated events, particularly for contracts drafted since January 2025, or that substantially increased costs make performance “unprofitable” or “very difficult,” but not impossible. The development of a new commercial contract, or the renewal or amendment of an existing one, presents an ideal opportunity to mitigate uncertainty around this point. Manufacturers may want to evaluate whether (or not) a contract needs a force majeure provision excusing performance because of tariffs, and insist on language that explicitly includes (or excludes) tariffs and identifies the circumstances under which they may (or may not) qualify as a triggering event. The details matter here. Read the article.

January 27, 2025

The Promise and the Peril: AI and Disruptive Technologies in Operations and Compliance

ACC Docket

The article covers the Department of Justice’s (DOJ) September 2024 revisions to the Evaluation of Corporate Compliance Programs (ECCP) that incorporate artificial intelligence (AI) management and the benefits and concerns of this technology. "The 2024 ECCP update is a lighthouse for companies navigating the uncertain waters of the rapidly evolving world of AI and disruptive technologies,” they wrote. “It warns of the perils—the rocks of malign use—and the DOJ’s focus on those perils. [I]t guides to relative safety—a harbor calmed by the breakwater of risk awareness and mitigation.” David and Kathryn emphasize that “[c]ompanies with exposure to AI and disruptive technologies” should understand the ECCP update and the implications arising from it. To read the article, click here.

November 7, 2024

A Blueprint for Targeted Enhancements to Corporate Compliance Programs

Corporate Counsel

The Department of Justice (DOJ) recently updated the Evaluation of Corporate Compliance Programs (ECCP) to direct prosecutors who are considering charges or resolutions to assess how a company addresses, among other topics, disruptive technologies and AI, self-disclosure initiatives, and the compliance function's access to corporate data. This enhanced guidance follows a pattern for ECCP amendments and reveals a trend toward an expectation of more proactive compliance efforts as a predicate for credit from prosecutors. Compliance stakeholders, therefore, can use this update as a blueprint for high-value program enhancements. Since 2017, the ECCP has been prosecutors' formal tool to judge compliance program adequacy. Largely presented as questions rather than prescriptions, the original ECCP provided "some important topics and sample questions that the [DOJ] … has frequently found relevant in evaluating a corporate compliance program." In 2019, the DOJ reorganized the ECCP into three topics—program design, implementation, and efficacy—and better aligned the questions with policies and priorities. In 2020, the DOJ substantively expanded the ECCP to address the compliance function's data use, role in M&A, and resourcing. In March 2023, the DOJ made two significant changes to address the data preservation and corporate compensation programs. AI and Disruptive Technologies. Beginning in early 2024, the DOJ previewed anticipated ECCP changes addressing AI (defined in OBM Memo M-24-10) and new technologies. It announced the Justice AI Initiative to accelerate DOJ's understanding and use of AI and noted the "promise" and "peril" of AI and its anticipated robust enforcement and accompanying stiffer penalties for offenses involving AI. The ECCP update, developed in consultation with compliance executives with AI expertise, examines how a company addresses these technologies in its compliance life cycle. Prosecutors will ask questions such as: How do the business and compliance function use technology? Is "management of risks related to use of AI and other new technologies integrated into" risk assessments? What actions is the company taking to "curb[] any potential negative or unintended consequences" and to "mitigat[e] the potential for deliberate or reckless misuse of technologies"? What "controls [are] in place to monitor and ensure [technologies'] trustworthiness, reliability, and use"? DOJ expects a company to thoroughly inventory its use of technology—being mindful of the broad definition of AI—across the entirety of the enterprise so that the organization knows everywhere it uses AI and how it uses AI. In addition, the business should assess its exposure to the malign use of AI against it. With this context, a company is expected to assess risks associated with internal use and external misuse of technology. (A company needing guidance on an AI-focused risk assessment can look to the NIST's AI Risk Management Framework.) The next step is the adoption of appropriate controls to mitigate these risks and proactively monitor the use of these technologies. Finally, the ECCP suggests the compliance function consider leveraging AI and other new technologies as part of its compliance work and self-assessment. Developments in Voluntary Self-Disclosure (VSD) Initiatives. The DOJ seized upon this ECCP update to further publicize significant new policies encouraging the reporting of misconduct.  Speak Up Programs.The ECCP's section on whistleblower programs and protections now aligns with the Corporate Whistleblower Awards Pilot Program (CWA), announced in August 2024, and other recent VSD initiatives. Under the CWA, the DOJ provides financial rewards to non-culpable whistleblowers who report misconduct to the government. Similarly, the DOJ's other VSD programs aim to entice self-reporting in exchange for more lenient treatment. The CWA and VSD initiatives expect robust speak up mechanisms and anti-retaliation regimes. In this regard, prosecutors will ask whether a "company encourage[s] and incentivize[s] reporting" or "chill[s] such reporting," how a company evaluates employee comfort with reporting, and how comprehensive a company's whistleblower and anti-retaliation training is. The ECCP places a premium on proactive efforts to support speaking up and no longer appears to offer full credit for a purely reactive program. The ECCP now looks at what a company does to affirmatively encourage and incentivize reporting. This, coupled with the CWA, appears to be the strongest suggestion to date that the DOJ is amenable to a company providing financial rewards to its own whistleblowers who report substantiated claims. Regardless, a company cannot merely rely on reporting metrics to determine efficacy of a speak up program and must instead find other means to assess whether employees are comfortable raising concerns. Finally, this version of the ECCP includes the most directive guidance on training. No longer will the DOJ look only at a company's training on speak up policies and mechanisms and the applicable anti-retaliation laws, prosecutors will examine whether the company trains its employees about external reporting mechanisms, like the CWA. Mergers & Acquisitions Safe Harbor Policy. The M&A Safe Harbor Policy announced in October 2023, provides that the DOJ presumptively will decline to charge an acquiring company that voluntarily discloses and remediates, in a timely manner, misconduct discovered during pre- or post-acquisition diligence. This policy embodies the DOJ's goal of encouraging effective diligence and integration. Relatedly, the ECCP now directs prosecutors to ask what role "compliance and risk management functions play[ed] … in designing and executing the integration strategy" and whether the integration strategy is reasonably designed "to ensure appropriate compliance oversight of the new business." To meet DOJ expectations, a company that engages in M&A activity should fully integrate the risk and compliance functions in its M&A processes to help with early identification, assessment, and remediation of compliance matters. Further, the company should invest in timely remediation to preserve options if misconduct is identified at an acquired company. The compliance function needs to be fully engaged to meet the M&A Safe Harbor Policy's strict deadlines on reporting and remediation to qualify for a declination. Compliance Access to Data. The DOJ has been increasingly focused on leveraging data in the compliance function to detect and prevent misconduct—the word "data" appears 12 times in the 2023 ECCP and more than 20 times in the 2024 ECCP. The 2024 ECCP makes clear that the DOJ will no longer ask if compliance has access to corporate data; it will ask what data compliance has access to. Accordingly, compliance should inventory available data sources across the enterprise and its access to them. The amended ECCP directs prosecutors to measure a company's commitment to such data usage. Prosecutors will now ask questions such as: Do "compliance personnel have knowledge of and means to access all relevant data sources … to create efficiencies … and measure the effectiveness of … compliance programs"? How do "the assets, resources, and technology available to compliance and risk management compare to those available elsewhere in the company"? The ECCP also clarifies that access to data alone is not sufficient; what compliance does with the data and what skilled resources are enlisted to assist with those tasks also matter. As a result, compliance needs access to staffing and other resources to permit effective use of data to assess both compliance with company policies and efficacy of the compliance program itself. The updated ECCP reflects both the DOJ's priorities and expanding expectations regarding compliance programs. Although the ECCP update covers additional topics, those addressed here offer opportunities for a strong return on the investment of compliance budget and effort. David E. Carney and Edward J. Heath are partners with Robinson+Cole and focus their practices on government enforcement, internal investigations, and corporate compliance programs. Reprinted with permission from the November 7, 2024 edition of Corporate Counsel© 2024 ALM Global Properties, LLC. All rights reserved. Further duplication without permission is prohibited, contact 877-256-2472 or asset-and-logo-licensing@alm.com

Legal Update: Department of Justice National Security Division Announces First-of-Its-Kind Declination under Its Voluntary Self-Disclosure Program teaser
June 4, 2024

Legal Update: Department of Justice National Security Division Announces First-of-Its-Kind Declination under Its Voluntary Self-Disclosure Program

Legal Update: Department of Justice Criminal Division Announces Voluntary Self-Disclosure Pilot Program for Culpable Individuals teaser
April 26, 2024

Legal Update: Department of Justice Criminal Division Announces Voluntary Self-Disclosure Pilot Program for Culpable Individuals

Legal Update: DOJ Announces New Whistleblower Compensation Pilot Program, Ratcheting Up Pressure on Corporate Voluntary Self-Disclosures teaser
March 12, 2024

Legal Update: DOJ Announces New Whistleblower Compensation Pilot Program, Ratcheting Up Pressure on Corporate Voluntary Self-Disclosures

January 19, 2024

Health Care Transactions and Civil Investigative Demands: What Third Parties Need to Know

Health Law Weekly

The article analyzes mergers and acquisitions (M&A) trends in health care markets, the increased scrutiny transactions face from the Federal Trade Commission and U.S. Department of Justice, Antitrust Division (collectively, the Agencies), and the Agencies’ use of civil investigate demands (CIDs) and their impact on the M&A process. “With the expected increase in health care merger activity comes the likelihood of greater investigatory scrutiny by government authorities,” they write, “Given the potentially significant implications of non-compliance or insufficient compliance, recipients of CIDs and subpoenas would do well to take those demands seriously and act promptly and comprehensively, including by engaging experienced counsel. To read the article, click here.

Legal Update: DOJ Announces Extension of Voluntary Self-Disclosure Guidance for Misconduct Discovered Through M&A Due Diligence teaser
October 6, 2023

Legal Update: DOJ Announces Extension of Voluntary Self-Disclosure Guidance for Misconduct Discovered Through M&A Due Diligence

November 7, 2024

A Blueprint for Targeted Enhancements to Corporate Compliance Programs

Corporate Counsel

The Department of Justice (DOJ) recently updated the Evaluation of Corporate Compliance Programs (ECCP) to direct prosecutors who are considering charges or resolutions to assess how a company addresses, among other topics, disruptive technologies and AI, self-disclosure initiatives, and the compliance function's access to corporate data. This enhanced guidance follows a pattern for ECCP amendments and reveals a trend toward an expectation of more proactive compliance efforts as a predicate for credit from prosecutors. Compliance stakeholders, therefore, can use this update as a blueprint for high-value program enhancements. Since 2017, the ECCP has been prosecutors' formal tool to judge compliance program adequacy. Largely presented as questions rather than prescriptions, the original ECCP provided "some important topics and sample questions that the [DOJ] … has frequently found relevant in evaluating a corporate compliance program." In 2019, the DOJ reorganized the ECCP into three topics—program design, implementation, and efficacy—and better aligned the questions with policies and priorities. In 2020, the DOJ substantively expanded the ECCP to address the compliance function's data use, role in M&A, and resourcing. In March 2023, the DOJ made two significant changes to address the data preservation and corporate compensation programs. AI and Disruptive Technologies. Beginning in early 2024, the DOJ previewed anticipated ECCP changes addressing AI (defined in OBM Memo M-24-10) and new technologies. It announced the Justice AI Initiative to accelerate DOJ's understanding and use of AI and noted the "promise" and "peril" of AI and its anticipated robust enforcement and accompanying stiffer penalties for offenses involving AI. The ECCP update, developed in consultation with compliance executives with AI expertise, examines how a company addresses these technologies in its compliance life cycle. Prosecutors will ask questions such as: How do the business and compliance function use technology? Is "management of risks related to use of AI and other new technologies integrated into" risk assessments? What actions is the company taking to "curb[] any potential negative or unintended consequences" and to "mitigat[e] the potential for deliberate or reckless misuse of technologies"? What "controls [are] in place to monitor and ensure [technologies'] trustworthiness, reliability, and use"? DOJ expects a company to thoroughly inventory its use of technology—being mindful of the broad definition of AI—across the entirety of the enterprise so that the organization knows everywhere it uses AI and how it uses AI. In addition, the business should assess its exposure to the malign use of AI against it. With this context, a company is expected to assess risks associated with internal use and external misuse of technology. (A company needing guidance on an AI-focused risk assessment can look to the NIST's AI Risk Management Framework.) The next step is the adoption of appropriate controls to mitigate these risks and proactively monitor the use of these technologies. Finally, the ECCP suggests the compliance function consider leveraging AI and other new technologies as part of its compliance work and self-assessment. Developments in Voluntary Self-Disclosure (VSD) Initiatives. The DOJ seized upon this ECCP update to further publicize significant new policies encouraging the reporting of misconduct.  Speak Up Programs.The ECCP's section on whistleblower programs and protections now aligns with the Corporate Whistleblower Awards Pilot Program (CWA), announced in August 2024, and other recent VSD initiatives. Under the CWA, the DOJ provides financial rewards to non-culpable whistleblowers who report misconduct to the government. Similarly, the DOJ's other VSD programs aim to entice self-reporting in exchange for more lenient treatment. The CWA and VSD initiatives expect robust speak up mechanisms and anti-retaliation regimes. In this regard, prosecutors will ask whether a "company encourage[s] and incentivize[s] reporting" or "chill[s] such reporting," how a company evaluates employee comfort with reporting, and how comprehensive a company's whistleblower and anti-retaliation training is. The ECCP places a premium on proactive efforts to support speaking up and no longer appears to offer full credit for a purely reactive program. The ECCP now looks at what a company does to affirmatively encourage and incentivize reporting. This, coupled with the CWA, appears to be the strongest suggestion to date that the DOJ is amenable to a company providing financial rewards to its own whistleblowers who report substantiated claims. Regardless, a company cannot merely rely on reporting metrics to determine efficacy of a speak up program and must instead find other means to assess whether employees are comfortable raising concerns. Finally, this version of the ECCP includes the most directive guidance on training. No longer will the DOJ look only at a company's training on speak up policies and mechanisms and the applicable anti-retaliation laws, prosecutors will examine whether the company trains its employees about external reporting mechanisms, like the CWA. Mergers & Acquisitions Safe Harbor Policy. The M&A Safe Harbor Policy announced in October 2023, provides that the DOJ presumptively will decline to charge an acquiring company that voluntarily discloses and remediates, in a timely manner, misconduct discovered during pre- or post-acquisition diligence. This policy embodies the DOJ's goal of encouraging effective diligence and integration. Relatedly, the ECCP now directs prosecutors to ask what role "compliance and risk management functions play[ed] … in designing and executing the integration strategy" and whether the integration strategy is reasonably designed "to ensure appropriate compliance oversight of the new business." To meet DOJ expectations, a company that engages in M&A activity should fully integrate the risk and compliance functions in its M&A processes to help with early identification, assessment, and remediation of compliance matters. Further, the company should invest in timely remediation to preserve options if misconduct is identified at an acquired company. The compliance function needs to be fully engaged to meet the M&A Safe Harbor Policy's strict deadlines on reporting and remediation to qualify for a declination. Compliance Access to Data. The DOJ has been increasingly focused on leveraging data in the compliance function to detect and prevent misconduct—the word "data" appears 12 times in the 2023 ECCP and more than 20 times in the 2024 ECCP. The 2024 ECCP makes clear that the DOJ will no longer ask if compliance has access to corporate data; it will ask what data compliance has access to. Accordingly, compliance should inventory available data sources across the enterprise and its access to them. The amended ECCP directs prosecutors to measure a company's commitment to such data usage. Prosecutors will now ask questions such as: Do "compliance personnel have knowledge of and means to access all relevant data sources … to create efficiencies … and measure the effectiveness of … compliance programs"? How do "the assets, resources, and technology available to compliance and risk management compare to those available elsewhere in the company"? The ECCP also clarifies that access to data alone is not sufficient; what compliance does with the data and what skilled resources are enlisted to assist with those tasks also matter. As a result, compliance needs access to staffing and other resources to permit effective use of data to assess both compliance with company policies and efficacy of the compliance program itself. The updated ECCP reflects both the DOJ's priorities and expanding expectations regarding compliance programs. Although the ECCP update covers additional topics, those addressed here offer opportunities for a strong return on the investment of compliance budget and effort. David E. Carney and Edward J. Heath are partners with Robinson+Cole and focus their practices on government enforcement, internal investigations, and corporate compliance programs. Reprinted with permission from the November 7, 2024 edition of Corporate Counsel© 2024 ALM Global Properties, LLC. All rights reserved. Further duplication without permission is prohibited, contact 877-256-2472 or asset-and-logo-licensing@alm.com

Legal Update: Department of Justice National Security Division Announces First-of-Its-Kind Declination under Its Voluntary Self-Disclosure Program teaser
June 4, 2024

Legal Update: Department of Justice National Security Division Announces First-of-Its-Kind Declination under Its Voluntary Self-Disclosure Program

Legal Update: Department of Justice Criminal Division Announces Voluntary Self-Disclosure Pilot Program for Culpable Individuals teaser
April 26, 2024

Legal Update: Department of Justice Criminal Division Announces Voluntary Self-Disclosure Pilot Program for Culpable Individuals

Legal Update: DOJ Announces New Whistleblower Compensation Pilot Program, Ratcheting Up Pressure on Corporate Voluntary Self-Disclosures teaser
March 12, 2024

Legal Update: DOJ Announces New Whistleblower Compensation Pilot Program, Ratcheting Up Pressure on Corporate Voluntary Self-Disclosures

January 19, 2024

Health Care Transactions and Civil Investigative Demands: What Third Parties Need to Know

Health Law Weekly

The article analyzes mergers and acquisitions (M&A) trends in health care markets, the increased scrutiny transactions face from the Federal Trade Commission and U.S. Department of Justice, Antitrust Division (collectively, the Agencies), and the Agencies’ use of civil investigate demands (CIDs) and their impact on the M&A process. “With the expected increase in health care merger activity comes the likelihood of greater investigatory scrutiny by government authorities,” they write, “Given the potentially significant implications of non-compliance or insufficient compliance, recipients of CIDs and subpoenas would do well to take those demands seriously and act promptly and comprehensively, including by engaging experienced counsel. To read the article, click here.

Legal Update: DOJ Announces Extension of Voluntary Self-Disclosure Guidance for Misconduct Discovered Through M&A Due Diligence teaser
October 6, 2023

Legal Update: DOJ Announces Extension of Voluntary Self-Disclosure Guidance for Misconduct Discovered Through M&A Due Diligence

News

March 25, 2025

Ed Heath Authors Article on Use of Force Majeure to Lessen Impact of Tariffs on Manufacturers

Business Litigation group chair and co-chair of the Government Enforcement + Internal Investigations team Edward Heath authored the article, “Here’s how commercial contracts can ease the cost burden of new tariffs impacting manufacturers,” published in the Hartford Business Journal on March 24, 2025. Just as force majeure gained significance during the pandemic, Ed suggests that same contractual provision could be a pivotal tool for manufacturers facing the increasing threat of new federal tariffs. Because the ripple effects of impending tariffs could be severe across supply chains, Ed poses the question: Could these new federal tariffs constitute a force majeure event that excuses, or at least delays, performance under a commercial contract? He points out that “the specific language used in the contract matters…” and that “[F]orce majeure provisions often list “government action” as a triggering event, and a tariff could qualify as such an action.” Ed suggests that manufacturers may want to evaluate whether contracts need a force majeure provision excusing performance because of tariffs, and insisting “on language that explicitly includes (or excludes) tariffs and identifies the circumstances under which they may (or may not) qualify as a triggering event.” Read the article.

Hartford Business Journal
January 30, 2025

David Carney and Kathryn Rattigan Co-Author ACC Docket Article Discussing the Promise and Peril of AI

ACC Docket
November 18, 2024

David Carney and Ed Heath Author Corporate Counsel Article Discussing Corporate Compliance Programs

March 25, 2025

Ed Heath Authors Article on Use of Force Majeure to Lessen Impact of Tariffs on Manufacturers

Business Litigation group chair and co-chair of the Government Enforcement + Internal Investigations team Edward Heath authored the article, “Here’s how commercial contracts can ease the cost burden of new tariffs impacting manufacturers,” published in the Hartford Business Journal on March 24, 2025. Just as force majeure gained significance during the pandemic, Ed suggests that same contractual provision could be a pivotal tool for manufacturers facing the increasing threat of new federal tariffs. Because the ripple effects of impending tariffs could be severe across supply chains, Ed poses the question: Could these new federal tariffs constitute a force majeure event that excuses, or at least delays, performance under a commercial contract? He points out that “the specific language used in the contract matters…” and that “[F]orce majeure provisions often list “government action” as a triggering event, and a tariff could qualify as such an action.” Ed suggests that manufacturers may want to evaluate whether contracts need a force majeure provision excusing performance because of tariffs, and insisting “on language that explicitly includes (or excludes) tariffs and identifies the circumstances under which they may (or may not) qualify as a triggering event.” Read the article.

Hartford Business Journal
January 30, 2025

David Carney and Kathryn Rattigan Co-Author ACC Docket Article Discussing the Promise and Peril of AI

ACC Docket
November 18, 2024

David Carney and Ed Heath Author Corporate Counsel Article Discussing Corporate Compliance Programs

January 23, 2024

Jen Driscoll, Conor Duffy, and Ed Heath Author Health Law Weekly Article on Health Care Transactions and Civil Investigative Demands

Health Law Weekly
October 1, 2020

Five Robinson+Cole Lawyers Recognized During Connecticut Legal Awards

Connecticut Law Tribune
January 6, 2020

Robinson+Cole Expands Government Enforcement and White-Collar Defense Team

January 23, 2024

Jen Driscoll, Conor Duffy, and Ed Heath Author Health Law Weekly Article on Health Care Transactions and Civil Investigative Demands

Health Law Weekly
October 1, 2020

Five Robinson+Cole Lawyers Recognized During Connecticut Legal Awards

Connecticut Law Tribune
January 6, 2020

Robinson+Cole Expands Government Enforcement and White-Collar Defense Team

Events

Past

The First 48 Hours: Crucial Decisions and Actions During the Critical First Hours of a Government Investigation

Apr 30 2025
HCCA 29th Annual Compliance Institute
Past

AI, Access to Corporate Data + the 2024 ECCP Update: A Benchmarking Discussion

Apr 15 2025
R+C Hosted Webinar
Past

The First 48 Hours: Crucial Decisions and Actions During the Critical First Hours of a Government Investigation

Apr 30 2025
HCCA 29th Annual Compliance Institute
Past

AI, Access to Corporate Data + the 2024 ECCP Update: A Benchmarking Discussion

Apr 15 2025
R+C Hosted Webinar
Past

Lab Enforcement Trends and Avoiding Compliance Pitfalls

Nov 15 2023
G2 Intelligence Lab Institute
Past

Lab Enforcement Trends and Avoiding Compliance Pitfalls

Nov 15 2023
G2 Intelligence Lab Institute

Firm Highlights

News
Natalie Ramsey Honored with Prestigious 2026 David T. Sykes Award

Bankruptcy + Reorganizations group co-chair Natalie Ramsey was recognized as the 2026 David T. Sykes Award recipient at the Eastern District of Pennsylvania Bankruptcy Conference’s (EDPABC) 36th Annual Forum on February 26, 2026. The award, which was co-presented by the EDPABC and the Consumer Bankruptcy Assistance Project (CBAP), is named after renowned bankruptcy attorney David T. Sykes and reflects Natalie’s excellence and integrity as a bankruptcy attorney, unsurpassed professionalism, mentorship of younger professionals, upholding of the reputation of the local bankruptcy bar, unwavering dedication to the bankruptcy community and the less fortunate in Philadelphia, and courtesy and respect for all. Natalie has been a member of the EDPABC since 1991 and served on its Board of Directors from 1999 - 2006, including as Chair in 2006. In addition, she has also been a member of the CBAP since 1993 and served as its President from 2012 - 2013.

News
Julianna Charpentier Recognized as an “Up & Coming Lawyer”
News
Robinson+Cole Recognized at 2026 Women, Influence & Power in Law Awards
News
Robinson+Cole Remains A “Best Place to Work in Connecticut”
News
Robinson+Cole Ushers in New Leadership for Nationally-Recognized Insurance + Reinsurance Practice

Robinson+Cole announced New York Partner Erica J. Kerstein has been named Chair of its Insurance + Reinsurance group, effective January 1, 2026. She succeeds Gregory P. Varga, who chaired the group since 2019. The strategic change to the leadership reinforces the firm’s thoughtful growth plan beyond its founding roots in Hartford and its commitment to providing exceptional client-focused service. “It’s a privilege to lead the firm’s nationally-recognized Insurance + Reinsurance group, a practice that has helped shape the insurance industry and this firm for generations,” said Kerstein. “Building on Greg’s leadership, I’m honored to carry this work forward and to do so as part of a team whose diversity and depth are a competitive advantage for our clients and their evolving needs navigating complex insurance coverage issues.” Celebrating over 180 years of practice, Robinson+Cole’s legacy in insurance law began alongside the establishment of leading insurance companies in the 19th century. The firm’s work was closely tied to these institutions, helping shape the legal landscape of the insurance industry from its earliest days. Over the decades, the firm’s lawyers have built a tradition of excellence and enduring relationships with leading insurers—a legacy now carried forward by more than 40 Insurance + Reinsurance lawyers practicing across six of Robinson+Cole’s office locations.   Insurance + Reinsurance group lawyers are helping to shape the insurance industry, representing and advising clients in disputes nationally and internationally involving cutting-edge issues, including on how to navigate the rapid evolution of artificial intelligence across the insurance ecosystem. As insurers accelerate their investment in artificial intelligence to address risk, efficiency, and regulatory complexity, Robinson+Cole has likewise made focused investments in AI‑enabled capabilities that enhance how its lawyers analyze data, manage complex matters, and deliver advice. Driven by client demand—including insurers seeking guidance on responsible, effective use of AI in claims, coverage, and litigation—the firm is integrating these technologies thoughtfully into its legal services while maintaining rigorous professional judgment, transparency, data security, and client confidentiality. Kerstein’s incisive, efficient, and responsive approach has enabled her to successfully litigate and arbitrate complex insurance matters—particularly in financial lines and commercial general liability, both domestically and internationally. Her experience also encompasses providing strategic counsel to clients in high-profile matters. Kerstein represents national and global insurers and reinsurers in state and federal courts across the United States, handling a wide range of complex coverage and bad faith disputes. Beyond her legal practice, Kerstein is an active member of The Bridge, an organization supporting the development of female talent in financial lines. “Greg Varga’s tenure as Chair of the firm’s Insurance practice has been exceptionally successful,” said Rhonda J. Tobin, Managing Partner at Robinson+Cole. “His vision, leadership, and experience not only elevated the practice and garnered national recognition, but it also opened new avenues for the firm’s growth and provides a strong foundation for Erica to carry forward.” Drawing on three decades of experience, Varga represents insurance companies in complex coverage and bad faith litigation, as well as arbitrations and appraisals. He chaired Robinson+Cole’s Insurance practice for 14 years over two terms, leading a team of more than 40 lawyers firmwide. Under his leadership, the group earned national recognition for its client-focused approach and became a thought leader in multiple areas of insurance law. “With Erica at the helm, our Insurance + Reinsurance group is poised to meet clients where they operate, extending our national and international reach,” said Varga. “Through working alongside her and leading the practice with her for the last few years, I am supremely confident that the group will continue to grow and thrive in the years to come as we continue to provide exceptional service to our valued clients. She will invest in data‑informed strategies, trial‑tested advocacy, and collaborative problem solving to keep our firm at the forefront of insurance law and practice.”

News
Robinson+Cole Names J. Michael Wirvin as Managing Partner

Robinson+Cole’s partnership has elected Boston Business Transactions Partner J. Michael Wirvin as its next Managing Partner, marking a pivotal moment in the firm’s 180-year history. Effective March 1, Wirvin will become the firm’s first Managing Partner based outside of Hartford, CT, reflecting Robinson+Cole’s continued evolution and expanding geographic footprint. His election underscores the firm’s deliberate, forward‑looking approach to leadership succession and long‑term strategic growth. Wirvin has served on Robinson+Cole’s Managing Committee since 2014, where he has played a central role in firm governance, strategic planning, and leadership succession, working closely with three managing partners through periods of unprecedented growth, market expansion, and changes in the legal industry. He is widely recognized for advising clients on complex domestic and cross‑border mergers and acquisitions, financings, and corporate structuring matters, with a particular focus on assisting U.S. and offshore companies navigate the legal, commercial, and cultural complexities of operating across jurisdictions. Wirvin also co‑chairs the firm’s International team. Wirvin has served as partner-in-charge of Robinson+Cole’s Boston office since 2014, reinforcing the firm’s culture, mentoring lawyers at all stages of their careers, and fostering cross‑disciplinary teamwork that strengthens client service. He recently helped lead the relocation of Robinson+Cole’s Boston office to 53 State Street, a premier downtown tower, creating a modern, light‑filled space designed to support employee well‑being with an energizing environment along with enhanced technology and workspaces that facilitate seamless remote and on-site collaboration and team building, while also promoting focused work. “It is a profound honor to be elected by my partners to serve as Managing Partner and lead this extraordinary team of lawyers and business professionals who raise the bar every day,” said Wirvin. “Our 180-year history is defined not merely by longevity, but by the trust we have earned, the results we have delivered, and the professionalism, mutual respect, and collegiality that have long defined our culture. As Managing Partner, I aim to build on that foundation—bringing strategic clarity and disciplined growth to our priorities, strengthening our national and international profile, investing in our people, and ensuring Robinson+Cole remains agile, cohesive, and well positioned to deliver practical, business‑minded solutions for clients in an increasingly complex and competitive environment.” Wirvin succeeds Rhonda J. Tobin, the firm’s first female Managing Partner, who led Robinson+Cole since 2021 and guided the firm through a period of significant transformation, growth, and innovation. Elected during the height of the COVID‑19 pandemic, Tobin brought to the role more than a decade of firm leadership experience, including service on the Managing Committee for 17 years and leadership of the firm’s Litigation Section for 14 years. During Tobin’s five-year tenure, Robinson+Cole successfully advanced and executed on a new Strategic Plan, improving profitability; expanding the firm’s New York, Boston, and Philadelphia offices; opening and growing offices in Washington, DC, and Austin, TX; and deepening leading national practices in affordable housing finance, bankruptcy, business transactions, capital markets and securities, intellectual property and technology, health care, managed care litigation, immigration, insurance, public finance, and real estate and development. Under Tobin’s leadership, the firm also strengthened its commitment to collaboration, inclusion, and talent development; launched meaningful DEIB initiatives; and made significant investments in technology, information governance, and workplace innovation. Additionally, the firm achieved top national rankings in Vault’s Best Law Firms to Work For six consecutive years. Robinson+Cole became the first Am Law 200 firm to strategically partner with agentic AI builder Newcode.ai and the first law firm in the United States to earn ARMA’s Verified Organization status, further reinforcing its position as an industry leader in innovation and information governance. Tobin’s leadership has been widely recognized, including being named Regional Managing Partner of the Year in Law.com’s 2025 New England Legal Awards and Managing Partner of the Year in the 2022 Women, Influence & Power in Law Awards. She will continue to serve as chair of the firm’s lateral growth committee and will continue her leadership roles and active involvement in Connecticut’s non-profit community and as Chairperson of the Connecticut Judicial Review Council. Commenting on Wirvin’s election, Tobin stated, “Mike’s deeply rooted presence and extensive leadership experience at Robinson+Cole make him an outstanding choice to lead our firm. I have known and worked closely with Mike for more than two decades, and there is no question that he is the right person to guide us forward as technological advancements and an evolving professional landscape present new opportunities. Mike is an exceptionally talented and experienced lawyer, and a trusted confidant whose insight I consistently relied on when facing strategic decisions. He is deeply respected by our lawyers and business professionals and brings a thoughtful, strategic perspective that will greatly benefit the firm. I look forward to the firm’s continued growth and success under his leadership.” Robinson+Cole also announced several additional leadership updates reflecting the firm’s continued focus on thoughtful succession planning, geographic expansion, and strategic growth. Davis Lee Wright, who is based in the firm’s Wilmington office, has been elected to the Managing Committee, joining Britt‑Marie K. Cole‑Johnson and Edward J. Heath who are resident in the Hartford office, Eric M. Kogan in Stamford, and Charles F. Martin III in Miami. The firm recently named New York partner Erica J. Kerstein as chair of its Insurance + Reinsurance group, Stamford partner Patrick W. Begos co-chair of its Managed Care + ERISA Litigation group, and Hartford partners  Conor O. Duffy and Robert S. Melvin and as Health Law group co-chair and Land Law Section co-chair, respectively. In addition, Kendra L. Berardi will succeed Wirvin as partner in charge of the Boston office.

News
Bankruptcy + Reorganizations Group Authors Key U.S. Sections for 2025 Chambers Insolvency Global Practice Guide
News
Robinson+Cole Integrates Thomson Reuters’ Deep Research into Newcode.ai Platform to Advance Secure, Verifiable Legal Research

Robinson+Cole has expanded its firmwide artificial intelligence (AI) capabilities by integrating Thomson Reuters’ Deep Research directly into Newcode.ai, the agentic AI platform implemented last year by the firm to support legal workflows across practices. With this integration, Robinson+Cole is one of only two law firms with direct access to the Deep Research API—and the only firm deploying it through Newcode.ai. Building on its 2025 partnership with Newcode.ai —making Robinson+Cole the first Am Law 200 firm to adopt the platform—the firm has continued to expand its AI capabilities as part of a broader strategy focused on secure deployment, ethical use, and seamless integration into daily legal work. The integration enables Robinson+Cole attorneys to conduct complex, multi‑step legal research and receive verifiable, citation‑backed responses grounded in trusted Thomson Reuters content. By embedding Deep Research into Newcode.ai, Robinson+Cole continues to build on its deliberate, governance‑first approach to AI adoption while delivering meaningful, practice‑ready innovation for its lawyers and clients. “Innovation at Robinson+Cole is grounded in client service, security, and practicality,” said J. Michael Wirvin, Managing Partner of Robinson+Cole. “By incorporating Thomson Reuters’ Deep Research directly into Newcode.ai, we are providing our lawyers with advanced research capabilities in a secure environment fully controlled by the firm that aligns with our standards for data governance, accuracy, and responsible AI use. This integration reflects our continued focus on adopting technology thoughtfully to support our attorneys and deliver value to our clients.” The addition of Deep Research allows attorneys to: Perform sophisticated legal research using agentic workflows that mirror real‑world legal reasoning Receive structured, verifiable responses grounded in Thomson Reuters data Streamline research processes while maintaining rigorous quality and accuracy standards Work entirely within Robinson+Cole’s firm‑controlled AI environment  “Our integration of the Thomson Reuters’ Deep Research API with Newcode represents a defining moment in our AI strategy,” said Chief Data Officer Jim Merrifield. "We are incredibly proud to be the first firm to bring this capability to life—unlocking the power of trusted legal data directly within the workflows our lawyers and business professionals rely on every day. This is exactly how we maximize our technology investments: by connecting best-in-class data sources through APIs into a unified platform, so the technology meets our people where they work, enhances their judgment, and accelerates better outcomes for our clients.” Robinson+Cole’s AI program is guided by firmwide policies, mandatory training, and ongoing oversight to ensure responsible use of emerging technologies. The firm’s approach emphasizes measured adoption, strong information governance, and alignment with client expectations, rather than one‑off experimentation. This latest enhancement underscores Robinson+Cole’s commitment to remaining forward‑thinking in its use of technology, while ensuring that innovation serves the firm’s clients, lawyers, and long‑term strategic goals.

News
Robinson+Cole’s People-First Culture Recognized in Vault’s 2027 Rankings
News
Erica Kerstein Brings Credibility and Business Perspective to New Role as Practice Group Chair

Insurance + Reinsurance group chair Erica J. Kerstein was featured in a Law.com column titled, “How I Made Practice Group Chair,” published on April 15, 2026. In the article, Erica discusses her new role as a practice group chair and how it has expanded her insight into not only the firm’s strategic vision and goals, but the reality of running a business and ensuring that current planning aligns with future goals. “The role provides a window into how individual practices fit into the firm’s overall strategy,” said Erica. “You’re thinking not just about today’s matters, but about where clients are headed, how the industry is changing, and how the firm positions itself to meet those needs.” In addition, Erica also identified “…strengthening client relationships, investing in our people, and staying ahead of emerging issues—particularly around technology and artificial intelligence in the insurance space…” as key priorities for the practice. Read the article.

News
Natalie Ramsey Honored with Prestigious 2026 David T. Sykes Award

Bankruptcy + Reorganizations group co-chair Natalie Ramsey was recognized as the 2026 David T. Sykes Award recipient at the Eastern District of Pennsylvania Bankruptcy Conference’s (EDPABC) 36th Annual Forum on February 26, 2026. The award, which was co-presented by the EDPABC and the Consumer Bankruptcy Assistance Project (CBAP), is named after renowned bankruptcy attorney David T. Sykes and reflects Natalie’s excellence and integrity as a bankruptcy attorney, unsurpassed professionalism, mentorship of younger professionals, upholding of the reputation of the local bankruptcy bar, unwavering dedication to the bankruptcy community and the less fortunate in Philadelphia, and courtesy and respect for all. Natalie has been a member of the EDPABC since 1991 and served on its Board of Directors from 1999 - 2006, including as Chair in 2006. In addition, she has also been a member of the CBAP since 1993 and served as its President from 2012 - 2013.

News
Julianna Charpentier Recognized as an “Up & Coming Lawyer”
News
Robinson+Cole Recognized at 2026 Women, Influence & Power in Law Awards
News
Robinson+Cole Remains A “Best Place to Work in Connecticut”
News
Robinson+Cole Ushers in New Leadership for Nationally-Recognized Insurance + Reinsurance Practice

Robinson+Cole announced New York Partner Erica J. Kerstein has been named Chair of its Insurance + Reinsurance group, effective January 1, 2026. She succeeds Gregory P. Varga, who chaired the group since 2019. The strategic change to the leadership reinforces the firm’s thoughtful growth plan beyond its founding roots in Hartford and its commitment to providing exceptional client-focused service. “It’s a privilege to lead the firm’s nationally-recognized Insurance + Reinsurance group, a practice that has helped shape the insurance industry and this firm for generations,” said Kerstein. “Building on Greg’s leadership, I’m honored to carry this work forward and to do so as part of a team whose diversity and depth are a competitive advantage for our clients and their evolving needs navigating complex insurance coverage issues.” Celebrating over 180 years of practice, Robinson+Cole’s legacy in insurance law began alongside the establishment of leading insurance companies in the 19th century. The firm’s work was closely tied to these institutions, helping shape the legal landscape of the insurance industry from its earliest days. Over the decades, the firm’s lawyers have built a tradition of excellence and enduring relationships with leading insurers—a legacy now carried forward by more than 40 Insurance + Reinsurance lawyers practicing across six of Robinson+Cole’s office locations.   Insurance + Reinsurance group lawyers are helping to shape the insurance industry, representing and advising clients in disputes nationally and internationally involving cutting-edge issues, including on how to navigate the rapid evolution of artificial intelligence across the insurance ecosystem. As insurers accelerate their investment in artificial intelligence to address risk, efficiency, and regulatory complexity, Robinson+Cole has likewise made focused investments in AI‑enabled capabilities that enhance how its lawyers analyze data, manage complex matters, and deliver advice. Driven by client demand—including insurers seeking guidance on responsible, effective use of AI in claims, coverage, and litigation—the firm is integrating these technologies thoughtfully into its legal services while maintaining rigorous professional judgment, transparency, data security, and client confidentiality. Kerstein’s incisive, efficient, and responsive approach has enabled her to successfully litigate and arbitrate complex insurance matters—particularly in financial lines and commercial general liability, both domestically and internationally. Her experience also encompasses providing strategic counsel to clients in high-profile matters. Kerstein represents national and global insurers and reinsurers in state and federal courts across the United States, handling a wide range of complex coverage and bad faith disputes. Beyond her legal practice, Kerstein is an active member of The Bridge, an organization supporting the development of female talent in financial lines. “Greg Varga’s tenure as Chair of the firm’s Insurance practice has been exceptionally successful,” said Rhonda J. Tobin, Managing Partner at Robinson+Cole. “His vision, leadership, and experience not only elevated the practice and garnered national recognition, but it also opened new avenues for the firm’s growth and provides a strong foundation for Erica to carry forward.” Drawing on three decades of experience, Varga represents insurance companies in complex coverage and bad faith litigation, as well as arbitrations and appraisals. He chaired Robinson+Cole’s Insurance practice for 14 years over two terms, leading a team of more than 40 lawyers firmwide. Under his leadership, the group earned national recognition for its client-focused approach and became a thought leader in multiple areas of insurance law. “With Erica at the helm, our Insurance + Reinsurance group is poised to meet clients where they operate, extending our national and international reach,” said Varga. “Through working alongside her and leading the practice with her for the last few years, I am supremely confident that the group will continue to grow and thrive in the years to come as we continue to provide exceptional service to our valued clients. She will invest in data‑informed strategies, trial‑tested advocacy, and collaborative problem solving to keep our firm at the forefront of insurance law and practice.”

News
Robinson+Cole Names J. Michael Wirvin as Managing Partner

Robinson+Cole’s partnership has elected Boston Business Transactions Partner J. Michael Wirvin as its next Managing Partner, marking a pivotal moment in the firm’s 180-year history. Effective March 1, Wirvin will become the firm’s first Managing Partner based outside of Hartford, CT, reflecting Robinson+Cole’s continued evolution and expanding geographic footprint. His election underscores the firm’s deliberate, forward‑looking approach to leadership succession and long‑term strategic growth. Wirvin has served on Robinson+Cole’s Managing Committee since 2014, where he has played a central role in firm governance, strategic planning, and leadership succession, working closely with three managing partners through periods of unprecedented growth, market expansion, and changes in the legal industry. He is widely recognized for advising clients on complex domestic and cross‑border mergers and acquisitions, financings, and corporate structuring matters, with a particular focus on assisting U.S. and offshore companies navigate the legal, commercial, and cultural complexities of operating across jurisdictions. Wirvin also co‑chairs the firm’s International team. Wirvin has served as partner-in-charge of Robinson+Cole’s Boston office since 2014, reinforcing the firm’s culture, mentoring lawyers at all stages of their careers, and fostering cross‑disciplinary teamwork that strengthens client service. He recently helped lead the relocation of Robinson+Cole’s Boston office to 53 State Street, a premier downtown tower, creating a modern, light‑filled space designed to support employee well‑being with an energizing environment along with enhanced technology and workspaces that facilitate seamless remote and on-site collaboration and team building, while also promoting focused work. “It is a profound honor to be elected by my partners to serve as Managing Partner and lead this extraordinary team of lawyers and business professionals who raise the bar every day,” said Wirvin. “Our 180-year history is defined not merely by longevity, but by the trust we have earned, the results we have delivered, and the professionalism, mutual respect, and collegiality that have long defined our culture. As Managing Partner, I aim to build on that foundation—bringing strategic clarity and disciplined growth to our priorities, strengthening our national and international profile, investing in our people, and ensuring Robinson+Cole remains agile, cohesive, and well positioned to deliver practical, business‑minded solutions for clients in an increasingly complex and competitive environment.” Wirvin succeeds Rhonda J. Tobin, the firm’s first female Managing Partner, who led Robinson+Cole since 2021 and guided the firm through a period of significant transformation, growth, and innovation. Elected during the height of the COVID‑19 pandemic, Tobin brought to the role more than a decade of firm leadership experience, including service on the Managing Committee for 17 years and leadership of the firm’s Litigation Section for 14 years. During Tobin’s five-year tenure, Robinson+Cole successfully advanced and executed on a new Strategic Plan, improving profitability; expanding the firm’s New York, Boston, and Philadelphia offices; opening and growing offices in Washington, DC, and Austin, TX; and deepening leading national practices in affordable housing finance, bankruptcy, business transactions, capital markets and securities, intellectual property and technology, health care, managed care litigation, immigration, insurance, public finance, and real estate and development. Under Tobin’s leadership, the firm also strengthened its commitment to collaboration, inclusion, and talent development; launched meaningful DEIB initiatives; and made significant investments in technology, information governance, and workplace innovation. Additionally, the firm achieved top national rankings in Vault’s Best Law Firms to Work For six consecutive years. Robinson+Cole became the first Am Law 200 firm to strategically partner with agentic AI builder Newcode.ai and the first law firm in the United States to earn ARMA’s Verified Organization status, further reinforcing its position as an industry leader in innovation and information governance. Tobin’s leadership has been widely recognized, including being named Regional Managing Partner of the Year in Law.com’s 2025 New England Legal Awards and Managing Partner of the Year in the 2022 Women, Influence & Power in Law Awards. She will continue to serve as chair of the firm’s lateral growth committee and will continue her leadership roles and active involvement in Connecticut’s non-profit community and as Chairperson of the Connecticut Judicial Review Council. Commenting on Wirvin’s election, Tobin stated, “Mike’s deeply rooted presence and extensive leadership experience at Robinson+Cole make him an outstanding choice to lead our firm. I have known and worked closely with Mike for more than two decades, and there is no question that he is the right person to guide us forward as technological advancements and an evolving professional landscape present new opportunities. Mike is an exceptionally talented and experienced lawyer, and a trusted confidant whose insight I consistently relied on when facing strategic decisions. He is deeply respected by our lawyers and business professionals and brings a thoughtful, strategic perspective that will greatly benefit the firm. I look forward to the firm’s continued growth and success under his leadership.” Robinson+Cole also announced several additional leadership updates reflecting the firm’s continued focus on thoughtful succession planning, geographic expansion, and strategic growth. Davis Lee Wright, who is based in the firm’s Wilmington office, has been elected to the Managing Committee, joining Britt‑Marie K. Cole‑Johnson and Edward J. Heath who are resident in the Hartford office, Eric M. Kogan in Stamford, and Charles F. Martin III in Miami. The firm recently named New York partner Erica J. Kerstein as chair of its Insurance + Reinsurance group, Stamford partner Patrick W. Begos co-chair of its Managed Care + ERISA Litigation group, and Hartford partners  Conor O. Duffy and Robert S. Melvin and as Health Law group co-chair and Land Law Section co-chair, respectively. In addition, Kendra L. Berardi will succeed Wirvin as partner in charge of the Boston office.

News
Bankruptcy + Reorganizations Group Authors Key U.S. Sections for 2025 Chambers Insolvency Global Practice Guide
News
Robinson+Cole Integrates Thomson Reuters’ Deep Research into Newcode.ai Platform to Advance Secure, Verifiable Legal Research

Robinson+Cole has expanded its firmwide artificial intelligence (AI) capabilities by integrating Thomson Reuters’ Deep Research directly into Newcode.ai, the agentic AI platform implemented last year by the firm to support legal workflows across practices. With this integration, Robinson+Cole is one of only two law firms with direct access to the Deep Research API—and the only firm deploying it through Newcode.ai. Building on its 2025 partnership with Newcode.ai —making Robinson+Cole the first Am Law 200 firm to adopt the platform—the firm has continued to expand its AI capabilities as part of a broader strategy focused on secure deployment, ethical use, and seamless integration into daily legal work. The integration enables Robinson+Cole attorneys to conduct complex, multi‑step legal research and receive verifiable, citation‑backed responses grounded in trusted Thomson Reuters content. By embedding Deep Research into Newcode.ai, Robinson+Cole continues to build on its deliberate, governance‑first approach to AI adoption while delivering meaningful, practice‑ready innovation for its lawyers and clients. “Innovation at Robinson+Cole is grounded in client service, security, and practicality,” said J. Michael Wirvin, Managing Partner of Robinson+Cole. “By incorporating Thomson Reuters’ Deep Research directly into Newcode.ai, we are providing our lawyers with advanced research capabilities in a secure environment fully controlled by the firm that aligns with our standards for data governance, accuracy, and responsible AI use. This integration reflects our continued focus on adopting technology thoughtfully to support our attorneys and deliver value to our clients.” The addition of Deep Research allows attorneys to: Perform sophisticated legal research using agentic workflows that mirror real‑world legal reasoning Receive structured, verifiable responses grounded in Thomson Reuters data Streamline research processes while maintaining rigorous quality and accuracy standards Work entirely within Robinson+Cole’s firm‑controlled AI environment  “Our integration of the Thomson Reuters’ Deep Research API with Newcode represents a defining moment in our AI strategy,” said Chief Data Officer Jim Merrifield. "We are incredibly proud to be the first firm to bring this capability to life—unlocking the power of trusted legal data directly within the workflows our lawyers and business professionals rely on every day. This is exactly how we maximize our technology investments: by connecting best-in-class data sources through APIs into a unified platform, so the technology meets our people where they work, enhances their judgment, and accelerates better outcomes for our clients.” Robinson+Cole’s AI program is guided by firmwide policies, mandatory training, and ongoing oversight to ensure responsible use of emerging technologies. The firm’s approach emphasizes measured adoption, strong information governance, and alignment with client expectations, rather than one‑off experimentation. This latest enhancement underscores Robinson+Cole’s commitment to remaining forward‑thinking in its use of technology, while ensuring that innovation serves the firm’s clients, lawyers, and long‑term strategic goals.

News
Robinson+Cole’s People-First Culture Recognized in Vault’s 2027 Rankings
News
Erica Kerstein Brings Credibility and Business Perspective to New Role as Practice Group Chair

Insurance + Reinsurance group chair Erica J. Kerstein was featured in a Law.com column titled, “How I Made Practice Group Chair,” published on April 15, 2026. In the article, Erica discusses her new role as a practice group chair and how it has expanded her insight into not only the firm’s strategic vision and goals, but the reality of running a business and ensuring that current planning aligns with future goals. “The role provides a window into how individual practices fit into the firm’s overall strategy,” said Erica. “You’re thinking not just about today’s matters, but about where clients are headed, how the industry is changing, and how the firm positions itself to meet those needs.” In addition, Erica also identified “…strengthening client relationships, investing in our people, and staying ahead of emerging issues—particularly around technology and artificial intelligence in the insurance space…” as key priorities for the practice. Read the article.

News
Natalie Ramsey Honored with Prestigious 2026 David T. Sykes Award

Bankruptcy + Reorganizations group co-chair Natalie Ramsey was recognized as the 2026 David T. Sykes Award recipient at the Eastern District of Pennsylvania Bankruptcy Conference’s (EDPABC) 36th Annual Forum on February 26, 2026. The award, which was co-presented by the EDPABC and the Consumer Bankruptcy Assistance Project (CBAP), is named after renowned bankruptcy attorney David T. Sykes and reflects Natalie’s excellence and integrity as a bankruptcy attorney, unsurpassed professionalism, mentorship of younger professionals, upholding of the reputation of the local bankruptcy bar, unwavering dedication to the bankruptcy community and the less fortunate in Philadelphia, and courtesy and respect for all. Natalie has been a member of the EDPABC since 1991 and served on its Board of Directors from 1999 - 2006, including as Chair in 2006. In addition, she has also been a member of the CBAP since 1993 and served as its President from 2012 - 2013.

News
Julianna Charpentier Recognized as an “Up & Coming Lawyer”
News
Robinson+Cole Recognized at 2026 Women, Influence & Power in Law Awards
News
Robinson+Cole Remains A “Best Place to Work in Connecticut”
News
Robinson+Cole Ushers in New Leadership for Nationally-Recognized Insurance + Reinsurance Practice

Robinson+Cole announced New York Partner Erica J. Kerstein has been named Chair of its Insurance + Reinsurance group, effective January 1, 2026. She succeeds Gregory P. Varga, who chaired the group since 2019. The strategic change to the leadership reinforces the firm’s thoughtful growth plan beyond its founding roots in Hartford and its commitment to providing exceptional client-focused service. “It’s a privilege to lead the firm’s nationally-recognized Insurance + Reinsurance group, a practice that has helped shape the insurance industry and this firm for generations,” said Kerstein. “Building on Greg’s leadership, I’m honored to carry this work forward and to do so as part of a team whose diversity and depth are a competitive advantage for our clients and their evolving needs navigating complex insurance coverage issues.” Celebrating over 180 years of practice, Robinson+Cole’s legacy in insurance law began alongside the establishment of leading insurance companies in the 19th century. The firm’s work was closely tied to these institutions, helping shape the legal landscape of the insurance industry from its earliest days. Over the decades, the firm’s lawyers have built a tradition of excellence and enduring relationships with leading insurers—a legacy now carried forward by more than 40 Insurance + Reinsurance lawyers practicing across six of Robinson+Cole’s office locations.   Insurance + Reinsurance group lawyers are helping to shape the insurance industry, representing and advising clients in disputes nationally and internationally involving cutting-edge issues, including on how to navigate the rapid evolution of artificial intelligence across the insurance ecosystem. As insurers accelerate their investment in artificial intelligence to address risk, efficiency, and regulatory complexity, Robinson+Cole has likewise made focused investments in AI‑enabled capabilities that enhance how its lawyers analyze data, manage complex matters, and deliver advice. Driven by client demand—including insurers seeking guidance on responsible, effective use of AI in claims, coverage, and litigation—the firm is integrating these technologies thoughtfully into its legal services while maintaining rigorous professional judgment, transparency, data security, and client confidentiality. Kerstein’s incisive, efficient, and responsive approach has enabled her to successfully litigate and arbitrate complex insurance matters—particularly in financial lines and commercial general liability, both domestically and internationally. Her experience also encompasses providing strategic counsel to clients in high-profile matters. Kerstein represents national and global insurers and reinsurers in state and federal courts across the United States, handling a wide range of complex coverage and bad faith disputes. Beyond her legal practice, Kerstein is an active member of The Bridge, an organization supporting the development of female talent in financial lines. “Greg Varga’s tenure as Chair of the firm’s Insurance practice has been exceptionally successful,” said Rhonda J. Tobin, Managing Partner at Robinson+Cole. “His vision, leadership, and experience not only elevated the practice and garnered national recognition, but it also opened new avenues for the firm’s growth and provides a strong foundation for Erica to carry forward.” Drawing on three decades of experience, Varga represents insurance companies in complex coverage and bad faith litigation, as well as arbitrations and appraisals. He chaired Robinson+Cole’s Insurance practice for 14 years over two terms, leading a team of more than 40 lawyers firmwide. Under his leadership, the group earned national recognition for its client-focused approach and became a thought leader in multiple areas of insurance law. “With Erica at the helm, our Insurance + Reinsurance group is poised to meet clients where they operate, extending our national and international reach,” said Varga. “Through working alongside her and leading the practice with her for the last few years, I am supremely confident that the group will continue to grow and thrive in the years to come as we continue to provide exceptional service to our valued clients. She will invest in data‑informed strategies, trial‑tested advocacy, and collaborative problem solving to keep our firm at the forefront of insurance law and practice.”

News
Robinson+Cole Names J. Michael Wirvin as Managing Partner

Robinson+Cole’s partnership has elected Boston Business Transactions Partner J. Michael Wirvin as its next Managing Partner, marking a pivotal moment in the firm’s 180-year history. Effective March 1, Wirvin will become the firm’s first Managing Partner based outside of Hartford, CT, reflecting Robinson+Cole’s continued evolution and expanding geographic footprint. His election underscores the firm’s deliberate, forward‑looking approach to leadership succession and long‑term strategic growth. Wirvin has served on Robinson+Cole’s Managing Committee since 2014, where he has played a central role in firm governance, strategic planning, and leadership succession, working closely with three managing partners through periods of unprecedented growth, market expansion, and changes in the legal industry. He is widely recognized for advising clients on complex domestic and cross‑border mergers and acquisitions, financings, and corporate structuring matters, with a particular focus on assisting U.S. and offshore companies navigate the legal, commercial, and cultural complexities of operating across jurisdictions. Wirvin also co‑chairs the firm’s International team. Wirvin has served as partner-in-charge of Robinson+Cole’s Boston office since 2014, reinforcing the firm’s culture, mentoring lawyers at all stages of their careers, and fostering cross‑disciplinary teamwork that strengthens client service. He recently helped lead the relocation of Robinson+Cole’s Boston office to 53 State Street, a premier downtown tower, creating a modern, light‑filled space designed to support employee well‑being with an energizing environment along with enhanced technology and workspaces that facilitate seamless remote and on-site collaboration and team building, while also promoting focused work. “It is a profound honor to be elected by my partners to serve as Managing Partner and lead this extraordinary team of lawyers and business professionals who raise the bar every day,” said Wirvin. “Our 180-year history is defined not merely by longevity, but by the trust we have earned, the results we have delivered, and the professionalism, mutual respect, and collegiality that have long defined our culture. As Managing Partner, I aim to build on that foundation—bringing strategic clarity and disciplined growth to our priorities, strengthening our national and international profile, investing in our people, and ensuring Robinson+Cole remains agile, cohesive, and well positioned to deliver practical, business‑minded solutions for clients in an increasingly complex and competitive environment.” Wirvin succeeds Rhonda J. Tobin, the firm’s first female Managing Partner, who led Robinson+Cole since 2021 and guided the firm through a period of significant transformation, growth, and innovation. Elected during the height of the COVID‑19 pandemic, Tobin brought to the role more than a decade of firm leadership experience, including service on the Managing Committee for 17 years and leadership of the firm’s Litigation Section for 14 years. During Tobin’s five-year tenure, Robinson+Cole successfully advanced and executed on a new Strategic Plan, improving profitability; expanding the firm’s New York, Boston, and Philadelphia offices; opening and growing offices in Washington, DC, and Austin, TX; and deepening leading national practices in affordable housing finance, bankruptcy, business transactions, capital markets and securities, intellectual property and technology, health care, managed care litigation, immigration, insurance, public finance, and real estate and development. Under Tobin’s leadership, the firm also strengthened its commitment to collaboration, inclusion, and talent development; launched meaningful DEIB initiatives; and made significant investments in technology, information governance, and workplace innovation. Additionally, the firm achieved top national rankings in Vault’s Best Law Firms to Work For six consecutive years. Robinson+Cole became the first Am Law 200 firm to strategically partner with agentic AI builder Newcode.ai and the first law firm in the United States to earn ARMA’s Verified Organization status, further reinforcing its position as an industry leader in innovation and information governance. Tobin’s leadership has been widely recognized, including being named Regional Managing Partner of the Year in Law.com’s 2025 New England Legal Awards and Managing Partner of the Year in the 2022 Women, Influence & Power in Law Awards. She will continue to serve as chair of the firm’s lateral growth committee and will continue her leadership roles and active involvement in Connecticut’s non-profit community and as Chairperson of the Connecticut Judicial Review Council. Commenting on Wirvin’s election, Tobin stated, “Mike’s deeply rooted presence and extensive leadership experience at Robinson+Cole make him an outstanding choice to lead our firm. I have known and worked closely with Mike for more than two decades, and there is no question that he is the right person to guide us forward as technological advancements and an evolving professional landscape present new opportunities. Mike is an exceptionally talented and experienced lawyer, and a trusted confidant whose insight I consistently relied on when facing strategic decisions. He is deeply respected by our lawyers and business professionals and brings a thoughtful, strategic perspective that will greatly benefit the firm. I look forward to the firm’s continued growth and success under his leadership.” Robinson+Cole also announced several additional leadership updates reflecting the firm’s continued focus on thoughtful succession planning, geographic expansion, and strategic growth. Davis Lee Wright, who is based in the firm’s Wilmington office, has been elected to the Managing Committee, joining Britt‑Marie K. Cole‑Johnson and Edward J. Heath who are resident in the Hartford office, Eric M. Kogan in Stamford, and Charles F. Martin III in Miami. The firm recently named New York partner Erica J. Kerstein as chair of its Insurance + Reinsurance group, Stamford partner Patrick W. Begos co-chair of its Managed Care + ERISA Litigation group, and Hartford partners  Conor O. Duffy and Robert S. Melvin and as Health Law group co-chair and Land Law Section co-chair, respectively. In addition, Kendra L. Berardi will succeed Wirvin as partner in charge of the Boston office.