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Peter Koski

Drawing on his experience as a senior DOJ official and leading international anti-corruption practitioner, Peter Koski represents companies and individuals in sensitive, high-stakes government and regulatory enforcement matters and internal investigations.

Peter has a depth of experience investigating, bringing to trial, and handling on appeal complex white collar matters involving the public and private sectors. He has handled an array of matters relating to foreign and domestic corruption, business and human rights, supply chain sourcing, cyber security, and violations of the federal laws governing elected and appointed officials. He has particular experience defending clients against alleged violations of the Trafficking Victims Protection Reauthorization Act (TVPRA), the Food, Drug, and Cosmetic Act (FDCA), and the Federal Election Campaign Act (FECA), as well as conspiracy, honest services fraud, bribery, gratuities, money laundering, obstruction of justice, and conflicts of interest.

Prior to joining the firm, Peter served as Deputy Chief of the U.S. Department of Justice’s Public Integrity Section, where he helped manage a team of over 30 attorneys responsible for investigating and prosecuting corruption across the country. In this capacity, he also argued complex constitutional issues before the federal courts of appeal. In over a decade of service in the Justice Department, Peter partnered with numerous U.S. Attorney’s Offices and worked closely with senior officials at over 25 federal agencies. Peter has tried over two dozen bench and jury trials, appeared in court in over a dozen districts across the country, and has handled corruption matters on five continents.

While in the U.S. Government and at Covington, Peter has worked closely with multilateral organizations, such as the Organisation for Economic Co-operation and Development (OECD). His previous experience with the OECD included serving as the U.S. representative on the Anti-Corruption Network Law Enforcement Advisory Board and the Advisory Group for the Anti-Corruption Network for Eastern Europe and Central Asia Thematic Review on Criminalization of Corruption.

Relying on this experience, Peter works with clients to develop effective due diligence programs related to sourcing and supply chains. He also analyzes the impact of regulator activity in this space, and develops strategies for engaging directly with regulators and NGOs. In this capacity, he helps companies assess the impact of Withhold Release Orders and counsels clients on the statutory regimes related to human rights and global supply chain issues.

Federal circuit courts are split on a core question of corruption law: whether state and local officials, and agents of organizations that contract with or receive benefits from the federal government, may lawfully accept gratuities.

It is generally a federal crime for state and local officials to act in their

Continue Reading Gratuity or Gift?  The Supreme Court May Soon Delineate the Difference

This week, the Department of Justice (DOJ) released a new memorandum from Deputy Attorney General Lisa Monaco updating its policies and procedures for criminal investigations involving Members of Congress and congressional staff.  

DOJ emphasized that investigations reaching Congress are important and “sensitive matters,” and explained that the additional guidance would

Continue Reading Newly Issued DOJ Guidance Adds Significant New Requirements for Criminal Investigations Relating to Congress

What happens in Arkansas does not stay in Arkansas.  Or at least not when federal prosecutors from the Department of Justice’s Public Integrity Section get involved.

A recent sentencing from Arkansas highlights the many options in DOJ’s toolkit to pursue “state-level” misconduct involving public officials.  In the case of former

Continue Reading Recent Arkansas Sentencing Highlights How Easily Federal Prosecutors Can Target State Campaign Finance Issues

Late last week, the Supreme Court indicated that it intends to review a challenge by Senator Ted Cruz (R-TX) to federal limits on the use of post-election contributions to repay pre-election loans that candidates make to their own campaigns.  This follows an earlier three-judge district court decision that struck down
Continue Reading Considering the Broader Implications of Cruz v. FEC

Over the past 10 days, the FEC has been quietly exercising authority reserved for when at least four Commissioners vote in favor of an action.  Since July 3, however, the FEC has only had three Commissioners.  This activity raises consequential questions about the FEC’s ability to act without a quorum,
Continue Reading The FEC Appears to be Exercising its Powers Without a Quorum

Every four years, prosecutors at the Department of Justice (“DOJ”) train their sights on money spent to influence the outcome of the presidential election—and those who spend it.  While the Federal Election Commission (FEC) has exclusive jurisdiction to penalize and enforce civil violations of the Federal Election Campaign Act (FECA),
Continue Reading Increased Enforcement Risk for Criminal Campaign Finance Violations