Jay Holtmeier


Holtmeier, Jay

Jay Holtmeier is a partner in the firm's Litigation/Controversy Department, and a member of the Investigations and Criminal Litigation Practice Group. He co-leads the firm's Foreign Corrupt Practices Act and Anti-Corruption Group and is a member of the Dodd-Frank Whistleblower Working Group. He joined the firm in 2004.


Mr. Holtmeier's breadth of experience as a litigator includes service as a federal prosecutor, a senior in-house attorney and a lawyer in private practice. Mr. Holtmeier represents institutions and individuals in complex government and internal investigations and matters of corporate governance and compliance. He has particular expertise in matters involving the Foreign Corrupt Practices Act (FCPA).

In FCPA matters, Mr. Holtmeier has represented clients in government and internal investigations involving conduct in Europe, Asia, the Middle East, Africa, Latin America and Australia. He regularly counsels clients facing difficult FCPA issues in a variety of business contexts, and he has assisted clients in numerous industries in developing and implementing FCPA compliance programs. He devotes substantial attention to advising clients on FCPA problems that arise in the context of mergers and acquisitions, joint ventures and other corporate transactions. He writes and speaks extensively on the subject and is a co-author, with partners Roger Witten and Kimberly Parker, of the leading treatise in the field, Complying with the Foreign Corrupt Practices Act (8th ed. 2013).

As a senior vice president and principal legal counsel with the Reuters Group, Mr. Holtmeier was responsible for all litigation and compliance matters in North and South America. As an assistant US Attorney for the Southern District of New York, he tried several cases to verdict and led extensive grand jury investigations of various crimes, including racketeering, securities fraud, murder, narcotics and counterfeiting. Significant prosecutions included United States v. Jose Muyet, et al., and United States v. Ronald Ocasio, et al., related cases involving more than twenty murders, for which Mr. Holtmeier received the Director's Award for Superior Performance from the Executive Office for US Attorneys, and United States v. Carol Bayless, which received national attention and calls for the impeachment of the presiding US District Judge.

Honors & Awards

  • Named a leader in the field of FCPA by Chambers Global: World's Leading Lawyers for Business in its 2015-2017 editions, with clients identifying him as a "very practical and very strategic" attorney with "incredible knowledge of what needs to be done and how the government is going to react to a situation." 
  • Recognized in the 2015-2017 editions of Chambers USA: America's Leading Lawyers for Business for his FCPA and white-collar crime litigation practices, with clients calling him "very experienced" with an "ability to anticipate issues and help put effective solutions in place."
  • Selected as one of the "Best Lawyers" in the area of criminal defense: white-collar in the 2013-2018 the Best Lawyers in America.
  • Recommended in the 2017 edition of The Legal 500 United States for corporate investigations and white-collar criminal defense.
  • Main Justice selected the firm's Foreign Corrupt Practices Act and Anti-Corruption Group as the recipient of its most prestigious honor, “Practice Group of the Year,” in 2012.

Publications & News


March 16, 2018

WilmerHale Recognized for Outstanding International Lawyers and Practices in Chambers Global 2018

In the 2018 edition of Chambers Global, 33 WilmerHale lawyers were named among “The World's Leading Lawyers for Business."

February 15, 2018

New DOJ FCPA Enforcement Policy Raises Difficult Questions For Companies Considering Voluntary Disclosures

This New York Law Journal article by Jay Holtmeier, Erin Sloane and Jeff Habenicht highlights a few of the uncertainties and potential pitfalls that may await a company deciding whether to take the significant step of voluntarily disclosing criminal conduct to prosecutors.

January 12, 2018

Global Anti-Bribery Year-in-Review: 2017 Developments and Predictions for 2018

This past year, which marked the 40th anniversary of the U.S. Foreign Corrupt Practices Act (“FCPA"), demonstrated that the FCPA continues to be a powerful tool in combating corruption abroad and encouraging compliance at global companies.

December 22, 2017

Global Magnitsky Sanctions Target Human Rights Abusers and Government Corruption Around the World

This article also appeared on the New York University School of Law Compliance and Enforcement Blog.

November 29, 2017

DOJ Announces New FCPA Corporate Enforcement Policy

Today, “[d]ue to the unique issues presented in FCPA matters,” Deputy Attorney General Rod Rosenstein announced a new FCPA corporate enforcement policy published in a revision to the United States Attorneys' Manual.

August 16, 2017

WilmerHale Lawyers Named Among the 2018 Best Lawyers in America®, Nine Recognized as Lawyers of the Year

Best Lawyers in America®—the oldest and most respected peer-review publication in the legal industry—recognizes 107 WilmerHale lawyers and names nine partners as Lawyers of the Year in its 24th edition.

July 18, 2017

Jay Holtmeier Elected to The City Bar Fund’s Board of Directors

The City Bar Fund supports several programs that help underserved communities secure legal representation; promote international justice efforts overseas; highlight the need for diversity and inclusion in the legal industry; mentor inner-city students looking to pursue legal careers; and offer substance abuse counseling to New York City lawyers.

June 9, 2017

The Legal 500 United States 2017 Recognizes 125 WilmerHale Lawyers Across 28 Practice Areas

The Legal 500 United States has released its 2017 rankings, recommending 125 WilmerHale lawyers—including 12 who are named to its elite “Leading Lawyers” list and two on its “Next Generation Lawyers” list—and 28 practice areas in its 11th edition.

May 26, 2017

WilmerHale Lawyers and Practices Recognized in 2017 Edition of Chambers USA

Chambers and Partners announced its rankings for the 2017 edition of Chambers USA: America's Leading Lawyers for Business, with WilmerHale listed among the nation's best in 50 practice area categories. Chambers also ranked 86 WilmerHale lawyers as leaders in their respective fields.

April 18, 2017

Evaluating FCPA Pilot Program: Lessons and Expectations

Kimberly A. Parker, Jay Holtmeier and Erin G.H. Sloane provided insights on the Department of Justice's Foreign Corrupt Practices Act pilot program in a recent article published as part of Law360's Expert Analysis series. The article assesses the program's goals, notable settlements and future.

Recent Highlights

  • Representation of a major financial institution in the Securities and Exchange Commission (SEC)'s first enforcement action involving the hiring of relatives of foreign officials.
  • Representation of a global manufacturer in enforcement actions by the Department of Justice, SEC, Department of Treasury, Department of Commerce and the US Navy involving allegations of improper kickbacks under the United Nations Oil-for-Food Program, violations of the FCPA and violations of US export laws.
  • Representation of a global airline in a non-prosecution agreement and a deferred prosecution agreement with the DOJ for alleged violations of the FCPA and Travel Act.
  • Representation of the chief executive officer of a public company in a non-prosecution agreement with the DOJ and a civil settlement with the SEC for alleged violations of the FCPA and US sanctions laws.
  • Representation of the audit committee of a global networking and communications company in a DOJ and SEC investigation of FCPA issues in Russia, Thailand and numerous other countries.
  • Representation of a major accounting firm in SEC and FDIC investigations relating to alleged financial reporting fraud at two financial institution clients.
  • Representation of the audit committee of a national food distributor in an investigation by the SEC into allegations of improper accounting.
  • Representation of the chief executive officer of a large newspaper in an Eastern District of New York grand jury investigation.
  • Representation of an accounting firm in investigations by the DOJ, the SEC, the PCAOB and the New York Attorney General into alleged financial reporting fraud at a major financial institution.
  • Representation of numerous companies and individuals in the pharmaceutical, financial services, media, manufacturing and other industries in numerous government and corporate internal investigations.

Professional Activities

In 2017, Mr. Holtmeier was elected to the Board of Directors of The City Bar Fund of the New York City Bar Association. In addition, Mr. Holtmeier is a member of the Board of Directors, and formerly the Chairman of the Board, of the New York City Bar Justice Center, the nonprofit legal services affiliate of the New York City Bar Association.


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JD, magna cum laude, Cornell Law School, 1990, Articles Editor, Cornell Law Review

BA, University of Minnesota, 1986

Bar Admissions

New York


The Hon. Phyllis A. Kravitch, US Court of Appeals for the Eleventh Circuit, 1990 - 1991

Government Experience

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