Michael Mugmon


Mugmon, Michael

Michael Mugmon is a partner in WilmerHale's San Francisco Bay Area office. His practice focuses broadly on crisis management for companies and individuals facing significant regulatory actions and litigation. Specifically, Mr. Mugmon regularly conducts internal investigations into potential misconduct, defends clients in government enforcement actions involving the US Attorney's Office, the US Securities and Exchange Commission, state attorney general's offices and the Financial Industry Regulatory Authority, and handles complex commercial and securities litigation in federal and state court. He has experience in matters related to financial fraud, breach of fiduciary duty, accounting irregularities, anti-money laundering, insider trading, the Foreign Corrupt Practices Act, compliance and risk management, internal controls, and disclosure issues.

Mr. Mugmon joined the firm's Washington, DC office in 2003 and moved to the Palo Alto office in 2007 as a founding member of that office's government investigations and litigation practice. The Daily Journal recently named him one of California's top 20 lawyers under 40.

A graduate of the University of Pennsylvania Law School, Mr. Mugmon also serves on the firm's Pro Bono and Community Service Committee and Ethics Committee, as well as on the Palo Alto office's Hiring Committee.

Honors & Awards

  • Named one of the "Top 20 Lawyers Under 40" in California by Daily Journal
  • Recognized as a "Rising Star" in the 2011-2017 editions of Northern California Super Lawyers
  • Burton Award for Legal Achievement, 2011

Representative Matters

  • Representing consumer healthcare technology company Theranos Inc. in various regulatory matters and class action litigation
  • Representing major Middle East-based company in responding to audit request and in enhancing compliance program, with focus on FCPA and export compliance
  • Representing major international technology company in SEC inquiry involving revenue recognition for cloud computing products
  • Representing major industrial and fabrication company in SEC inquiry involving inventory accounting issues
  • Conducted internal investigation on behalf of mobile payments and identity verification company into allegations of potential money laundering and violations of the anti-bribery provisions of the Foreign Corrupt Practices Act
  • Represented Pacific Gas & Electric Co. in connection with development of regulatory compliance model
  • Representing international investment bank/broker-dealer in California Attorney General inquiry involving underwriting of mortgage-backed securities 
  • Represented audit committee of board of directors of California retail company in connection with potential suppression of insurance reserves and misconduct by company management 

Recent Successes

  • Successfully resolved US Securities and Exchange Commission inquiry on behalf of individual investigated for potential insider trading by obtaining letter closing investigation without adverse action
  • Successfully resolved US Securities and Exchange Commission inquiry relating into initial public offering on behalf of major social media company by obtaining letter closing investigation without adverse action
  • Successfully resolved US Securities and Exchange Commission inquiry involving accounting practices related to litigation reserves on behalf of major public semiconductor company by obtaining letter closing investigation without adverse action
  • Successfully resolved US Securities and Exchange Commission inquiry involving adequate disclosure of principal transactions on behalf of investment management firm by obtaining letter closing investigation without adverse action
  • Obtained dismissal of class action against major public semiconductor company concerning its acquisition of competitor in California state court
  • Represented major broker-dealer in FINRA inquiry concerning sales of variable life insurance contracts, or "variable life settlements"
  • Achieved extremely favorable settlements for two investment banks in multi-plaintiff challenge to short-selling practices in San Francisco County Superior Court

Professional Activities

Mr. Mugmon is a member of the American Bar Association and the Bars of California, Maryland and the District of Columbia.

Pro Bono and Community Service

  • Serving as a Lead Adjudicator for San Francisco Neighborhood Courts alternative dispute resolution program operated by San Francisco District Attorney's office
  • Achieved 35-year reduction in sentence for California inmate who received improper gang enhancement of indeterminate length to sentence for role as armed robbery getaway driver
  • Represented California gang member charged with RICO and VICAR conspiracy to commit murder in federal district court in Northern District of California
  • Represented California inmate in successful parole proceedings after California Board of Parole Hearings had denied his 15 previous applications
  • Secured U-VISA for Mexican immigrant who was victim of domestic abuse

Publications & News


February 11, 2016

Energy Sector Alert Series: Climate Change Disclosures in 2016

A sweeping federal rule from the Environmental Protection Agency, aggressive enforcement by a state attorney general, a landmark international accord, and the persistent demands of investors are combining to bring increased scrutiny to public companies' climate change-related disclosures.

July 17, 2015

Litigating with the SEC

A chapter written by Douglas Davison, Michael Mugmon and Chris Johnstone, published in the Practising Law Institute's SEC Compliance and Enforcement Answer Book 2015

February 2, 2015

"We Intend to Resolve the Ambiguities": The SEC Issues Some Surprising Guidance on Fraud Liability in the Wake of Janus

An article by Matthew Martens, Michael Mugmon, Jaclyn Moyer, Timothy Perry and Laura Goodall, published in Bloomberg BNA's Securities Regulation & Law Report on February 2, 2015.

November 19, 2014

Scalia’s Deference Argument Could Have Dramatic Effects

An article by Matthew Martens, Michael Mugmon, Jaclyn Moyer and Saurabh Sangvhi, published by Law360 on November 18, 2014.

November 10, 2014

The rise of white collar wiretaps

An article by Michael Mugmon and Tim Perry, published in the November 10, 2014 edition of the Daily Journal.

October 9, 2014

SEC Enforcement Actions Emphasize Importance of Stock Ownership Reporting Obligations for Public Companies and Insiders

On September 10, 2014, the Securities and Exchange Commission announced charges against 28 officers, directors and major stockholders of public companies for violating Section 16(a) and/or Section 13(d) of the Securities Exchange Act of 1934, as amended.

April 4, 2014

Some prefer litigation when the SEC calls

An article by Michael Mugmon and Chris Johnstone, published in the April 4, 2014 edition of The Daily Journal.

March 13, 2014

Supreme Court Issues Decision Analyzing Whether Misrepresentation is “in Connection with” Purchase or Sale of Covered Security

On February 26, 2014, in Chadbourne & Parke LLP v. Troice et al., the Supreme Court narrowed the definition of “in connection with” as that term is used in the Securities Litigation Uniform Standards Act of 1998 (SLUSA).

January 21, 2014

SB 538: Overhauled anti-securities fraud provision

An article by Michael Mugmon and Matthew Benedetto, published in the January 21, 2014 edition of The Daily Journal.

October 3, 2013

California Overhauls State Anti-Securities Fraud Statute

On September 23, 2013, Governor Jerry Brown signed into law Senate Bill 538—which overhauls the anti-fraud provision of the California Securities Law of 1968, and will likely make it more difficult for would-be plaintiffs to maintain lawsuits for securities fraud.


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JD, cum laude, University of Pennsylvania Law School, 2002, Editor-in-Chief, University of Pennsylvania Law Review; Arthur Littleton and H. Clayton Louderback Legal Writing Instructor

BA, magna cum laude, University of Pennsylvania, 1999, Phi Beta Kappa

Bar Admissions


District of Columbia






The Hon. Ruggero J. Aldisert, US Court of Appeals for the Third Circuit, 2002 - 2003

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