Cost escalation has emerged as a significant, and prevalent, issue in the construction industry, driven by post-pandemic global supply chain disruptions, inflationary pressures, and geopolitical events. As escalation claims continue to reshape the industry, it is essential for project owners, employers, contractors, and legal professionals to understand the root causes of escalation claims and how to adopt practical, evidence-based strategies to successfully navigate disputes on construction contracts.

In her latest article, Secretariat Associate Director Clare Ashworth examines:

  • What are escalation claims, and why are they so common now?
  • Key global events driving construction cost escalation.
  • How escalation manifests in disputes and how it’s measured.
Read the Article

Managing Director Allan Ingraham was featured in a recent article in The Boston Globe providing economic analysis of WNBA player compensation and demonstrating that players are significantly underpaid relative to the league’s current market value.

Through an economist’s lens, Allan examined WNBA salaries three ways—based on the media rights deal, team valuations, and revenue split. Each analysis revealed that players were being paid far less than fair market value. The average WNBA salary last season was $107,000, but Allan’s analysis shows it should be no less than $750,000.

“In the last five years, we’ve seen exponential growth in the value of the WNBA,” Allan explained. “There’s been exponentially more interest. There’s been more fans, there’s been more revenues, and… that growth occurred largely under one CBA that didn’t necessarily anticipate the growth.”

Allan noted that WNBA team valuations have soared to a combined $3.6 billion, and expansion franchises are now valued at $250 million. He emphasized that while jointly negotiating media rights deals with the NBA has provided benefits, it has also undervalued player salaries. Looking ahead, Allan stressed the importance of future agreements that can anticipate continued growth.

“A correction likely needs to be made. And then going forward, one of the things that [we] will be looking for is how subsequent CBAs try to anticipate the future growth in league revenues under future CBAs.”

Read Allan’s full analysis in The Boston Globe here (subscription required).

by Jeanne Gee

As federal regulatory priorities narrow under the Trump administration, state attorneys general and financial regulators are preparing to take on a more active role in white collar and securities enforcement. With the Department of Justice (DOJ) and the Securities and Exchange Commission (SEC) recalibrating their focus, states such as New York and California are asserting their authority to fill gaps in corporate oversight.

Federal Enforcement Realignment

The DOJ is undergoing significant structural and strategic changes. As an example, many prosecutors are being reassigned from white collar units to immigration enforcement. Several specialized units have been dissolved, including the National Security Division’s Corporate Enforcement Unit, the Foreign Influence Task Force, and Task Force KleptoCapture.[1] In May 2025, Matthew Galeotti (“Galeotti”), Head of the Criminal Division, issued a memorandum to DOJ Criminal Division personnel outlining new priorities in white collar crime enforcement, where he noted the priority would be on “focused, fair, and efficient white-collar enforcement” as it “promotes American economic and national security interests while protecting American taxpayers, investors, consumers, and businesses.”[2]

At the SEC, leadership under Chair Paul Atkins has signaled a shift toward a more constrained regulatory posture. Atkins has emphasized a return to the agency’s core mission, which includes investor protection, efficient markets, and capital formation, while scaling back enforcement activity in areas such as internal accounting controls.[3] The SEC is also placing less emphasis on enforcement statistics, instead focusing on impact and efficiency. Notably, the Commission has reinstated a requirement that formal orders of investigation be approved by the full Commission, rather than delegated to the Division of Enforcement.[4]

These changes represent a marked retreat from the more expansive enforcement approach seen in recent years, particularly in areas involving national security, corruption, and environmental disclosures. As Galeotti noted in his May 2025 memorandum, “overbroad and unchecked corporate and white-collar enforcement burdens U.S. businesses and harms U.S. interests.”[5]

New York Increases Enforcement Activity

In response to the shifting federal landscape, New York enforcement officials have expressed a clear intent to expand their oversight role to address some gaps in federal enforcement. The Martin Act grants both the New York Attorney General and District Attorney sweeping powers to investigate and prosecute financial fraud without having to prove intent. Attorney General Letitia James has stated that her office will continue to investigate and prosecute crimes regardless of federal policy direction.[6] She has reaffirmed the office’s responsibility to enforce state laws independently. Manhattan District Attorney Alvin Bragg has emphasized that local prosecutors are well equipped to handle complex financial crimes and may, in some instances, be best positioned to do so. His office also relies on the Martin Act to pursue corporate misconduct aggressively.

The New York Department of Financial Services (DFS) is also preparing for a greater enforcement role. Superintendent Adrienne Harris has said that a rollback in federal regulation will likely increase the volume of consumer protection cases brought by her office. She has noted that while the DFS is not ideological, it will act where new gaps emerge due to diminished federal partnership.[7]

California’s Enforcement Focus

California’s enforcement strategy is expected to differ in focus, but not in intensity. California Attorney General Robert Bonta (Bonta) has aligned with multistate coalitions challenging federal rollbacks and is prioritizing action in three areas: climate enforcement, antitrust scrutiny of mergers, and artificial intelligence regulation. In the area of corporate fraud, in April 2025 he issued a legal advisory reminding businesses operating in California that the FCPA remains binding federal law and violations are actionable under California’s Unfair Competition Law.[8] Attorney General Bonta has warned companies to be prepared for continued enforcement of anti-corruption laws in California.

In its most recent strategic plan, the California Department of Financial Protection and Innovation (DFPI) has stated its priorities are grounded in three core values: safety and soundness, responsible innovation and economic mobility.[9] As such, DFPI will continue its oversight over the financial services ecosystem, expand its reach, modernize its approach to regulating high risk investments, and strengthen its partnership with the California Attorney General through its Crypto Scam Tracker.[10]

SEC Under Paul Atkins

SEC Chair Paul Atkins has taken steps to reduce the regulatory burden on public companies and streamline oversight in emerging sectors such as digital assets. He has stated his commitment to a more coherent and principles-based approach to crypto regulation and has expressed skepticism about what he views as politicization in financial markets.[11] [12]

Atkins has publicly opposed the SEC’s climate disclosure rule and has suggested that the agency’s use of staff guidance has been inconsistent with proper rulemaking procedures.[13] He has proposed revisiting the structure of the Enforcement Division and cutting post-financial-crisis units such as the Asset Management Unit and the Market Abuse Unit. Additionally, he has championed the creation of a Wells-like advisory committee to review SEC enforcement policies and procedures.[14]

These changes reflect a broader shift away from expansive rulemaking and aggressive enforcement, in favor of narrower and more traditional regulatory objectives consistent with the Commission’s core objective of protecting individual investors.

Strategic Implications for Corporate Legal Teams

The growing role of state-level enforcement carries significant implications for companies, boards, and in-house legal departments. Effective response strategies should prioritize independence, credibility, and timely action. Internal investigations must be approached with objectivity and seriousness, particularly when allegations involve senior leadership.

In matters where multiple enforcement agencies may initiate parallel investigations—such as the SEC, DOJ, and state regulators—organizations must be prepared to navigate differing priorities, timelines, and legal requirements. This includes controlling the flow of factual information to management, preserving all relevant data including mobile and messaging communications, and ensuring coordinated efforts among internal and external legal teams.

Five Key Takeaways for Compliance and Legal Professionals

  1. State-level enforcement is rising
    State attorneys general and financial regulators are stepping in to fill the void left by federal enforcement pullbacks. Organizations should monitor developments in jurisdictions such as New York and California, where agencies are expanding their reach.
  2. Credible internal investigations are essential
    Investigations must be led by independent counsel and supported by forensic experts with relevant experience. Boards and audit committees should be prepared to act swiftly and with full transparency.
  3. Multi-agency coordination requires discipline
    When facing parallel investigations, maintaining consistency across communications and disclosures is critical. Legal teams must manage timelines, protect attorney work product, and anticipate information-sharing constraints between agencies.
  4. Preserve mobile and alternative communications data
    Evidence increasingly resides outside of email, including encrypted apps and messaging platforms. Early and comprehensive data preservation is a core expectation of regulators and auditors.
  5. Engage proactively and strategically
    Offering joint presentations or proffers to agencies such as the SEC and DOJ can help avoid duplicative processes and reduce investigative risk. Defense counsel should prioritize agency coordination where possible and help guide discussions toward resolution.

Companies operating in this rapidly shifting environment should move quickly to strengthen their internal governance, prepare for dual-track enforcement, and stay informed as state and federal enforcement dynamics continue to evolve.

[1] https://news.bloomberglaw.com/us-law-week/bondi-scales-back-us-justice-department-white-collar-enforcement
[2] https://www.justice.gov/opa/media/1400141/dl?inline
[3] https://www.sec.gov/newsroom/speeches-statements/testimony-atkins-060325
[4] https://www.sec.gov/files/rules/final/2025/33-11366.pdf
[5] https://www.justice.gov/opa/media/1400141/dl?inline
[6] https://ag.ny.gov/press-release/2025/attorney-general-james-releases-joint-statement-10-state-attorneys-general-state
[7] https://www.ft.com/content/e7db351b-bd38-415a-87cd-a13aad2762a3
[8] https://www.skadden.com/insights/publications/2025/04/california-attorney-general-warns
[9] https://dfpi.ca.gov/about/what-we-do/strategic-plan/
[10] https://dfpi.ca.gov/press_release/dfpi-strengthens-partnership-with-ca-department-of-justice-to-stop-crypto-scams-and-prevent-consumer-financial-loss/
[11] https://www.sec.gov/newsroom/speeches-statements/atkins-digital-finance-revolution-073125
[12] https://www.regulatoryandcompliance.com/2025/04/the-sec-under-paul-atkins-what-to-expect-for-registered-and-private-offerings-climate-related-disclosure-consolidated-audit-trail-digital-assets-and-agency-re-organization
[13] https://www.daypitney.com/Update-US-SEC-Votes-to-Drop-Defense-of-Climate-Disclosure-Rules
[14] https://www.cov.com/-/media/files/corporate/publications/2025/03/paul-atkins-past-speeches-offer-a-glimpse-into-secs-future.pdf

by Amran Nawaz, Shalabh Gupta, Charlie Chetwood, and Ben Hornan

This is the first article in a series between Hogan Lovells and Secretariat on legal and expert issues that arise in sports disputes.

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The 25/26 Premier League season has only recently started, but disputes involving the Premier League and its clubs have been ongoing for several seasons. Those disputes have brought the Premier League’s dispute resolution mechanisms into sharp focus.

This article focuses on the two main dispute mechanisms under the Premier League’s Rules (the “PL Rules”): disciplinary proceedings under Rule W (like those initiated against Everton FC and Manchester City FC in recent years); and arbitration under Rule X (like the now-settled dispute between the Premier League and Manchester City FC in connection with the Associated Party Transaction Rules). The article also looks at the role of experts in both sets of proceedings.

Chapter 1: Disciplinary proceedings under Rule W

The Board’s powers

When clubs are suspected of having breached the Premier League’s Rules, the Board of the Premier League has various powers to investigate, request information, and require clubs to produce documents.

The Board also has its own disciplinary powers to deal with breaches of the Rules. Those powers range from issuing a reprimand to imposing penalties and fines.[1] However, for substantial breaches, the Board typically refers the matter to an Independent Commission.

Referral to an independent commission

The Board commences proceedings before an Independent Commission by sending a complaint to the Chair of the Premier League’s Judicial Panel as well as to the respondent club.

Following receipt of the complaint, the Chair of the Judicial Panel appoints the Independent Commission. The Independent Commission will comprise of three members from the Premier League’s Disciplinary Panel (one of whom will act as Chair).

Assuming the respondent denies the complaint, the Chair of the Commission will set down a procedure for the conduct of the complaint. The Chair’s procedural powers include:

  • providing the Board and respondent club further opportunities to set out their case in writing;
  • requiring the parties to conduct reasonable and proportionate searches for, and to disclose documents relevant to the issues;
  • allowing the parties to exchange reports from experts on relevant issues, for example, on financial, accounting, valuation, and sporting issues;
  • allowing the parties to exchange witness statements on factual issues relevant to the complaint; and
  • ordering interim relief.

Typically, a formal hearing will be held at which the parties will set out their arguments, witnesses and experts will be cross-examined, and the Independent Commission will ask questions. The length of the proceedings and hearing will reflect the extent of the documentary, witness and expert evidence submitted by the Parties.

The decision and sanction

The Independent Commission makes its decision unanimously or by majority. It must be satisfied that the complaint has been proven on the balance of probabilities.

The Independent Commission has a wide range of sanctioning powers against clubs. After considering any mitigating or aggravating factors, amongst various options, the Independent Commission may:

  • impose an unlimited fine;
  • order the respondent club to pay unlimited compensation to any person, entity, or club;
  • deduct points; and
  • recommend that the Premier League expel the respondent club from Premier League membership.

However, the Independent Commission’s decision is not final because it may be appealed (by either the club or the Board) to an Appeal Board.

Appeals

The appeal must be made within 14 days of the decision that is the subject of the appeal. It will be heard by an Appeal Board of three members.

The purpose of the appeal is to review the evidence set out in the Independent Commission proceedings. Parties cannot rely on new evidence unless granted permission from the Appeal Board. The appeal will typically involve a hearing at which each Party’s lawyers will make arguments. 

The Appeal Board has the power to allow, dismiss, or vary the decision of the order made at first instance.

Subject to arbitration, the decision of an Appeal Board is final.

Chapter 2: Arbitration under Rule X

Under the PL Rules, membership of the Premier League constitutes an arbitration agreement, meaning that each club agrees to submit all disputes that arise between each club, and between the Premier League and each club, to arbitration seated in England and Wales.

This is a separate dispute resolution procedure to disciplinary proceedings under Rule W. It means that (in theory) the Premier League and its clubs cannot pursue claims against each other in the courts of England & Wales.

The Premier League distinguishes between three different kinds of disputes:

  • Decisions of Independent Commissions or Appeal Boards (“Disciplinary Disputes”);
  • Exercise of the Board’s discretion (“Board Disputes”); and
  • Other disputes arising from the PL Rules or otherwise.

Disciplinary Disputes can be reviewed by an arbitral tribunal only in limited circumstances, including where the decision was reached as a result of fraud, malice or bad faith, procedural errors, a perverse interpretation of the law and/or was one which could not reasonably have been reached by any Independent Commission or Appeal Board.

The grounds for reviewing a Board Dispute are even more limited. They include where the decision was reached as a result of fraud, malice or bad faith, contrary to English law, or could not have been reached by any reasonable Board.

The outcome of arbitration is final and binding on all concerned parties, save for the limited grounds for appeal to the courts set out in the Arbitration Act. Parties are unable to appeal on a point of law.

Chapter 3: The Role of Experts

The role of experts in Premier League disputes is growing. As financial structures around clubs become more complex—spanning multi-jurisdictional ownership, sophisticated sponsorship arrangements, and contested valuation issues—Independent Commissions and arbitral tribunals are increasingly reliant on financial, accounting, and valuation experts to help them navigate the issues in dispute. Questions such as whether a sponsorship deal reflects fair market value often cannot be answered without expert evidence.

Under the Premier League Rules, tribunals may permit the exchange of expert reports, the cross-examination of experts at hearings, and the testing of their methodologies through questioning. The procedural framework, however, is narrow. Expert evidence is usually confined to what is strictly necessary to resolve compliance or sanction issues. The process is designed to be efficient, confidential, and focused on preserving the integrity of the competition.

By comparison, the IBA Rules on the Taking of Evidence in International Arbitration set out a more expansive role for experts. Party-appointed experts must disclose their instructions, assumptions, and methodologies, enabling tribunals to test competing analyses on equal footing. Cross-examination and direct questioning by the tribunal are integral, clarifying technical issues and maximising the reliability of the evidence. Often the experts appointed by both parties prepare joint-expert reports or are cross-examined by the tribunal together (also known as hot-tubbing) to narrow down the differences in their opinions. In practice, expert analysis often sits at the heart of the tribunal’s deliberations, particularly in disputes involving financial modelling and valuation.

Conclusion

The PL Rules provide a structured framework for addressing alleged breaches and disputes between clubs and the Premier League by individuals and clubs.

As the financial dimensions of cases grow in scale and complexity, the role of experts in Premier League disputes is set to increase.

The question remains how far the existing procedural tools under the PL Rules can accommodate that evolution.

[1]  Under its summary jurisdiction, the Board can impose a fine not exceeding £100,000, or, in the case of a managerial breach, a sum which set out in a tariff or a penalty agreed  with the League Managers Association.

Explore more insights from our Global Sports Consulting team, connect with our experts, and follow Secretariat for the latest in sports business strategy. 

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Secretariat is thrilled to announce that 20 of our experts have been recognized as premier Construction professionals in the Lexology Index 2025 Thought Leaders – Construction report, including a leading number of Global Elite Thought Leaders (12).  

Lexology Index (formerly Who’s Who Legal), one of the world’s most trusted and highly regarded publications, provides an in-depth look into the world’s elite and upcoming construction practitioners in its 2025 Thought Leaders – Construction report. The recognized experts have been nominated by clients and peers, gaining recognition for their unparalleled expertise, experience, and ability to innovate, inspire, and go above and beyond for their clients. 

Secretariat’s substantial presence throughout Lexology’s 2025 Thought Leaders – Construction report underscores the caliber, influence, and esteemed reputation of our firm and global experts alike, and the instrumental role we continue to play in helping clients navigate the most complex, high-stakes matters that are shaping the future of the Construction industry.  

Read the Report

Congratulations to our recognized Construction Expert Thought Leaders:  

Secretariat is proud to share that 11 of our experts have been named as USA Thought Leaders in Lexology Index’s 2026 listing. This honor underscores the depth of expertise, innovation, and leadership that our professionals bring to the legal world, and the tremendous impact they have on clients and peers alike. 

Congratulations to:  

  • Meera Wagman 
    • Arbitration Expert Witnesses 
    • Construction – Quantum Delay & Technical 
    • Construction Expert Witnesses 
  • Neil Gaudion 
    • Arbitration Expert Witnesses 
    • Construction – Quantum Delay & Technical 
    • Construction Expert Witnesses 
  • Don Harvey 
    • Arbitration Expert Witnesses 
    • Construction – Quantum Delay & Technical 
    • Construction Expert Witnesses 
  • Ted Scott 
    • Arbitration Expert Witnesses 
    • Construction – Quantum Delay & Technical 
    • Construction Expert Witnesses 
  • Garrett Rush 
    • Arbitration Expert Witnesses 
    • Financial Advisory and Valuation – Quantum of Damages
    • Mining – Experts  
  • Kiran Sequeira 
    • Arbitration Expert Witnesses 
    • Financial Advisory and Valuation – Quantum of Damages 
  • Carrie Distler 
    • Commercial Litigation – Expert Witnesses 
    • IP – Experts 
  • Thomas Fertitta 
    • Construction – Quantum Delay & Technical 
    • Construction Expert Witnesses 
  • Mike Kling 
    • Construction – Quantum Delay & Technical 
    • Construction Expert Witnesses 

View Lexology’s listing in full here.  

Secretariat Managing Director Tamika Tremaglio has been named as one of the Most Powerful Women in Washington by Washingtonian Magazine. 

The annual listing showcases women who exemplify power and influence across D.C.’s most critical fields.

Tamika was recognized as a renowned business leader, highlighting her current role helping spearhead the expansion of Secretariat’s new global Sports Consulting practice and her experiences as executive director of the National Basketball Players Association and managing principal for Deloitte’s Greater Washington office. 

“Being named among Washington’s most powerful women is both an honor and a charge,” said Ms. Tremaglio. “Power, at its best, is stewardship — not dominance. It’s the quiet conviction to open doors, to make the table longer, to leave no voice unheard. I am grateful to stand among Washington’s most powerful women, but prouder still to be part of a generation redefining what power looks like.”

We are thrilled to celebrate Ms. Tremaglio’s leadership and her continued impact across the business, legal, and sports landscapes.

Read the full listing here.

by Pablo Varas

The abandoned transaction between Novant Health (Novant) and Community Hospital System (CHS) for two North Carolina (NC) hospitals received substantial attention from the media, lawyers, and economists. Even though an initial district court ruling rejected FTC’s preliminary injunction request, a subsequent court decision pushed the parties to abandon the deal. This case was not a plain-vanilla deal. Some features made the antitrust discussion and the first instance ruling of particular interest, particularly for economic analysis of hospital mergers and considering deal-specific factors.

In February 2023, Novant agreed to purchase Lake Norman Regional Medical Center (LNR) and Davis Regional Psychiatric Hospital (Davis) from CHS. Novant is one of the largest health systems in NC, operating multiple facilities across the state. On the other hand, CHS is a national for-profit health system, and the LNR and Davis facilities represent CHS’s most important assets in NC. CHS wanted to sell LNR because the facility needed substantial capital investments, which CHS was not willing to make. The Davis facility was a former acute care hospital that, due to its poor performance and investment needs, was repurposed as a psychiatric facility. The transaction between Novant and CHS aimed to improve Novant’s competitive edge relative to Atrium Health (Atrium), NC’s largest health system.

The FTC decided to challenge the transaction in January 2024, initiating an administrative procedure and subsequently filing a complaint to block the deal in the US District Court for the Western District of NC. The FTC argued that LNR and Novant’s nearby hospital are head-to-head competitors and the main hospital options in the Eastern Lake Norman area, the relevant geographic market for the transaction. As such, LNR exerts competitive pressure on Novant, limiting Novant’s ability to increase prices, the FTC argued.

In June 2024, the district court ruled in favor of CHS and Novant by rejecting FTC’s preliminary injunction request. However, the FTC appealed at the US Court of Appeals for the 4th Circuit, which, in a divided decision, reverted the district court’s decision and granted the request to enjoin the CHS-Novant deal. Following this setback, the parties abandoned the deal. The appeals court’s ruling does not explain why the district court decision had to be reverted, with the dissenting judge explicitly agreeing with the district court that the injunction is not in the best public interest.

Three features make this case of particular interest for antitrust economic analysis. First, one of the parties, CHS, had decided to exit the market and stopped actively competing. Second, the transaction seemed to have meaningful potential pro-competitive effects. Third, the buyer, Novant, committed not to increase prices for three years after the transaction.

The economic analysis of a standard hospital merger assumes that if the deal is blocked, the parties will continue operating. Hence, the analysis focuses on the competitive effects of the deal compared to the status quo. However, in this particular transaction, CHS stated its plan to exit the market and stop investing additional capital in LNR. There have been several hospital transactions where the parties have put forward the failing firm argument to support the deal. A recent example is John Muir Health’s failed takeover of San Ramon Regional Medical Center in California. The possibility that, in the near future, one of the parties may exit the market changes the but-for-world when evaluating the effect of the merger on consumers. That is, in these situations, the economic analysis must consider a scenario where the likely-exiting hospital is not available to consumers.

Importantly, CHS ended up selling LNR and Davis to Iredell Health System, another NC-based hospital system, in early 2025. The fact that there was another potential buyer for CHS’s assets in NC poses a challenge for future hospital merger deals claiming the failing firm argument. The FTC, and likely the courts, may increase the bar to consider the closing of a hospital, and the lack of alternative buyers, a credible threat when assessing a proposed transaction.   

A second feature of the CHS-Novant deal was the potential pro-competitive effects of the transaction. LNR had experienced an overall deteriorating process and CHS has no interest in continuing to invest in this facility. As such, the transaction was likely to enhance LNR’s competition pressure and increase Novant’s competitive edge against Atrium, the dominant health system in NC. Stronger competition between the state’s two largest health systems was a factor to consider in evaluating the antitrust effects of Novant’s acquisition of LNR. Even if the transaction would increase concentration in the local geographic market, there is value in the competition effect in the broader market. This factor gained relevance given the alleged declining status of LNR and its lack of ability to effectively compete with Atrium’s facilities.

A final interesting feature of the CHS-Novant proposed deal is the expected hospital price increases following the acquisition. Economic analysis of a hospital merger involving head-to-head competitors is likely to find that prices would increase if the merger took place. Potential price increases are the main concerns regarding any hospital merger. The underlying reasoning is that the combined entity would increase its bargaining leverage when negotiating contract terms with health insurance companies, allowing the merged system to push for higher prices. Novant’s management committed to maintaining current LNR prices during the three years after the acquisition, posing a challenge to the consideration of the merger’s price effect. In a way, the empirical analysis may conclude that the merged entity would have the incentives and ability to meaningfully increase prices; however, deals’ features or market realities, like Novant’s management commitment, may assuage one of the critical concerns about any hospital merger. How credible such commitments are is subject to judges’ and courts’ consideration.

The appeals court ruling unfortunately offers no clues as to the arguments that supported its decision to enjoin the transaction. Notably, the district court and the dissenting appeal judge sided with the parties on the relevance of the failing firm factor, the pro-competitive effects of the transaction, and the no-price increase commitment. Those factors and considerations will likely get more attention in the economic analysis of future proposed hospital transactions.

This article is featured in the Fall 2025 issue of Economists Ink.

Secretariat is pleased to share that 87 of our experts have been named in the Lexology Index 2025 Consulting Expert Reports series, achieving recognition as global industry leaders across several key categories: 

  • Competition Economists 
  • Construction – Quantum, Delay & Technical 
  • Financial Advisory and Valuation – Quantum of Damage 
  • Forensic Accountants 

Lexology’s 2025 Consulting Expert Reports identify the premier litigation consulting experts in the global market, determined through their rigorous research process as well as nominations from clients and peers.   

Secretariat’s continued inclusion in Lexology’s prestigious rankings underscores our firm’s credibility, technical excellence, and expert leadership across consulting sectors. 

Read Lexology’s full 2025 Consulting Expert reports here.  

Competition Economists 

Recommended Consulting Experts  

USA  
  • David Argue is a distinguished competition economist renowned for his expert analysis and compelling testimony in complex healthcare merger reviews and antitrust litigation. 
  • John Morris is a leading authority in the competition market, with over 20 years of experience analysing mergers and investigating abuse of dominance matters in the US energy sector. 
  • Philip Nelson is a leading authority in antitrust economics, widely respected for combining rigorous academic insight with high-impact regulatory experience from his senior role at the FTC. 
  • With more than 40 years of experience, Robert Stoner stands out as a leading authority for delivering first-rate expert testimony in landmark merger and monopolisation cases and providing strategic guidance on complex class actions. 
  • Su Sun is a clear leader in the field of competition economics, with deep expertise in merger review, price fixing and abuse of dominance matters. His experience spans antitrust investigations and litigation across the US and China. 
  • Keith Waehrer comes highly recommended by peers and clients, thanks to his brilliant work on major mergers and anti-monopoly disputes in the telecoms, financial services and aviation industries, among others. 
  • Lexology Index says: Matthew Wright earns plaudits for his deep understanding of competition economics involving monopolisation, damages estimation and merger analysis across an array of industries, including transport, pharmaceuticals and consumer goods, among others. 

Construction – Quantum, Delay & Technical 

Recommended Consulting Experts  

Australia 
  • Jonathan Brown is a highly respected director with experience in quantum expert services, known for his meticulous and pragmatic approach to quantity surveying, valuation of prolongation costs, disruption, and loss of productivity. 
  • Joel Glover is a distinguished chartered quantity surveyor with over 18 years of experience in cost consulting and dispute resolution. He is praised for his “quality of written work,” which sets him apart in the field of quantum experts. 
  • Charmy Patel earns widespread praise for her vast experience providing quantum analysis on disputes arising from major infrastructure projects, both domestically and abroad. 
  • With a focus on dispute resolution, Paul Roberts provides expert quantum opinions to clients in the construction industry. His experience spans a wide range of projects, making him a trusted adviser in complex matters. 
  • Les Ross is an accomplished expert with a well-developed quantum practice, possessing over four decades of experience in high-stakes construction disputes. He is widely held to be a leading authority in the field, regularly advising on complex claims across infrastructure, energy and natural resources projects. 
Canada 
  • With over three decades of experience, Christopher Larkin is singled out for his top-tier practice navigating complex cross-border delay and quantum matters arising from major construction and infrastructure projects.
  • Robert Poole has built an impressive reputation as a top-tier expert witness and is touted for his “ability to quickly distil the facts” and analyse “voluminous materials”. 
England 
  • Oliver Barnes is a well-known name in global construction disputes, with nearly 30 years’ experience. He earns praise for his incisive delay analysis, pragmatism and unparalleled scheduling expertise. 
  • Sena Gbedemah is a well-regarded delay expert who takes a “hands-on approach” to high-value construction disputes in the transport, energy and technology sectors. Sources say, “He communicates in a calm and effective way to ensure the right approach is taken.” 
  • Described as “razor-sharp” and “excellent on the stand,” quantum expert Terry Hawkins is praised for his diligent approach to complex construction disputes, both domestically and abroad. 
  • Liam Holder is “an outstanding construction expert,” recognised for his extensive experience in quantifying damages. His involvement in high-stakes international disputes highlights his capabilities in evaluating complex concepts, making him a valuable asset in the construction sector. 
  • Celebrated for his forensic precision in resolving complex construction disputes, Mehmet Karakoc is a leading delay expert who advises global infrastructure and energy clients across 35 countries. 
  • Nicolas Noyer possesses over 25 years of experience in the construction industry, specialising in quantum analysis and has provided expert advice on projects across the Americas and EMEA region, covering sectors such as oil and gas and infrastructure. 
  • Rhiann Storey commands a spectacular reputation in the construction industry, particularly in dispute resolution. She is praised for her ability to “communicate very well with clients,” ensuring clarity in complex matters. Her dual qualifications as a Fellow of the Royal Institution of Chartered Surveyors and the Chartered Institute of Arbitrators enhance her expertise. 
  • George Taft is acknowledged as a “leading expert” in quantum claims, with extensive experience in international arbitration. His “approachable nature and strong analytical skills” make him a valuable asset in high-stakes construction disputes. 
  • Mark Vaughan-Jones is a trusted expert in programming and delay, valued for his rigorous forensic approach and dual expertise in quantum and scheduling across high-stakes construction disputes in the UK, Europe, and the Middle East. 
Hong Kong 
  • With over three decades of experience in quantity surveying and quantum analysis, Mike Allen is sought after internationally for his “precision and accuracy” in complex valuations. 
  • Ben Burley is a highly regarded delay expert with a strong international presence across the APAC and EMEA regions. He is lauded by peers and clients alike for his “ability to foresee issues and advise on strategies to tackle them ahead of time”. 
  • With a unique expertise in the programming and planning in the construction sector, Alex Ho remains a trusted advisor for complex matters and disputes involving a delay element in Hong Kong. 
  • Jeffrey Wong possesses over 25 years of experience providing loss of profits and valuations analysis in domestic and international construction and infrastructure disputes. 
Singapore 
  • With over 10 years of experience, Brian Bowie is a favourite with peers and clients for his expertise in delay and productivity analysis for complex construction projects. His work includes offshore oil & gas, tunnelling, and wastewater treatment. 
  • Amit Garg is widely recognised as one of the foremost authorities in quantum delay analysis and construction disputes, with industry leaders praising him as “amongst the best experts in the industry”. 
  • Matthew Wills is a key name when it comes to complex quantum and delay matters in the infrastructure projects internationally in a variety of sectors, including energy and oil. 
  • John Lancaster was also recognized as Recommended consulting expert in Lexology’s report.  
UAE 
  • Manus Bradley is a highly regarded delay expert, known for his sharp forensic analysis and decades of hands-on experience resolving complex scheduling disputes on major construction and engineering projects worldwide. 
  • Ian Greenhough is highly recommended by sources who praise his “detailed understanding of all quantum-related matters” and further highlight that he is “easy to work with, fair and has a common-sense approach”. 
  • Taoufik Lachheb is a distinguished expert in delay and quantum analysis, with over 25 years’ experience in the engineering and construction market. He is known for his skilled and collaborative approach to disputes across oil and gas, shipbuilding and infrastructure sectors worldwide. 
  • Mike Saulsbury is “a stand-out delay expert” who brings “meticulous attention to detail and deep understanding of construction schedules and project timelines” to large-scale disputes. 
  • Kagan Aktas was also recognized as Recommended consulting expert in Lexology’s report.  
USA 
  • Bryan Byrd is an internationally sought-after cost and scheduling expert with a wealth of experience in construction, engineering and procurement projects, where he assists in a range of matters, including risk analysis and cost control. 
  • Dan Clark is highly commended by market leaders thanks to “his ability to drill down through a complex amount of data and identify key points that are useful to the claim”. 
  • Thomas Fertitta is a longstanding fixture in the construction market, with over three decades of experience advising on complex commercial projects. He is highly regarded for his ability to foresee project risks and craft strategic and persuasive analyses in high-stakes disputes. 
  • Tom Gaines is a globally recognised authority in claim pricing, cost analysis and delay assessment for construction projects. With over two decades of experience, he has delivered expert testimony in high-stakes disputes involving airports, healthcare facilities and major infrastructure developments. 
  • Nelson Gallardo is a renowned testifying expert witness specialising in delay and damages issues, who enjoys a strong reputation for his work in high-value construction disputes across Latin America and the United States. 
  • Neil Gaudion receives widespread praise from sources as being a “sharp, detail-oriented and well-prepared” practitioner who possesses decades of experience serving as an expert witness for major energy-related construction projects and disputes. 
  • With over 25 years of experience, Don Harvey has acted in some of the most complex and high-profile construction disputes. His meticulous approach and sharp insights have earned him the spot among top-notch expert witnesses in the field. 
  • Wayne Kalayjian is extremely well-known for his deep expertise in domestic and international design and construction projects across the energy, transport and healthcare industries. 
  • Clients applaud Michael Kling for his deep expertise in skilfully navigating complex construction disputes involving quantum, delay and technical issues. One source highlights his “thorough research skills”. 
  • Ted Scott is a “well-rounded and well-spoken expert” who wins praise in the market for his “unparalleled technical evaluations” and “excellent testifying skills”. 
  • Chris Sullivan is a specialist in schedule delay and quantum analysis, assisting clients in complex construction projects across sectors ranging from healthcare and utilities to energy and infrastructure. 
  • Thanks to his over two decades of experience as a quantum and delay expert, Brian Triche impresses peers and clients alike with his propensity for “organisation, strategic thinking and effective presentation” when handling high-stakes construction disputes. 
  • With a strong background in project management, Meera Wagman is a sought-after expert for delay and disruption analyses in global, high-profile construction projects. 
  • Chris Brindisi was also recognized as Recommended consulting expert in Lexology’s report.  

Future Leaders 

Canada 
  • Etienne Berge is a “diligent and detail-oriented” delay and quantum expert with over 15 years of experience providing services to project owners and contractors in Canada and internationally. He is praised for his ability to “quickly understand the issues and the client’s requirements” and ” impressive ability to review and analyse large quantities of data”. 
England 
  • Tosh Masson is a rising star in construction disputes, with a sharp focus on delay analysis. He is praised for being “truly on top of the detail,” delivering “excellent report writing and analytics” across complex infrastructure and engineering claims. 
  • Gareth McDermott is praised for his “methodical and meticulous approach” to valuing construction claims. His nearly 20 years of experience in international projects make him an exemplary expert witness in quantum matters. 
  • Michael Pogue commands presence in the construction disputes arena, known for his expertise in complex quantum matters. He “consistently demonstrates professionalism, precision and a strategic approach,” with analysis that is “meticulous”. 
  • Kaz Rozputynski is a trusted expert in the construction and engineering industries, offering exceptional services related to programming and scheduling of complex construction projects. He has garnered acclaim from peers for his “responsiveness and attention to detail in his delay analysis”. 
Singapore 
  • Yasir Kadhim enjoys a fantastic reputation in the market, with peers and clients praising him for the quality of his reports. He is often involved in complex disputes concerning delay claims in the construction sector. 
  • Vivienne Li earns plaudits on the market for her “remarkably skilled, practical and well-reasoned approach to delay analysis” and “consistently clear and logically structured explanations”. 
USA 
  • Kelsey Bishop is a first-rate construction specialist who comes highly recommended for her delay analysis and contract review experience across a wealth of projects across an array of industries, including energy and transport to property and utilities. 
  • A fast-rising name in the construction disputes space, Madison Clark brings exceptional clarity and analytical depth to delay analysis. She is recognised for her “detailed and qualified analysis of project schedules” and ability to “identify the causes and consequences of changes” with precision. 
  • Described as “a pleasure to work with,” Zackery Kilgore excels in providing expert advice on complex construction matters, particularly on programming and scheduling for major projects worldwide. 
UAE 
  • Stuart Allan was recognized as a Future Leader consulting expert in Lexology’s report.  

Financial Advisory and Valuation – Quantum of Damages 

Global Elite Thought Leaders 

Canada 
  • Chris Milburn is a distinguished damages and valuations expert with deep expertise navigating major financial investigations and disputes arising from the energy and natural resources, financial services and property sectors, among others. 
  • With over four decades of experience, Howard Rosen is “amongst the best in the industry and well-liked by clients,” thanks to his deep knowledge of business valuations and damages quantification in high-stakes international arbitrations. 
USA 
  • Kiran Sequeira is described as “simply the best in the industry,” with over 20 years of experience providing quantum analysis in international disputes. His ability to “anchor discussions on key points” makes him a highly regarded expert witness in complex cases. 

Recommended Consulting Experts  

Canada 
  • Julius Koo is a pre-eminent business valuation and damages quantification expert who is celebrated in the market for his “diligent approach and levelheadedness” to high-value arbitration and litigation proceedings. 
England 
  • Liam Holder is among the world’s foremost quantum experts. With over 30 years of experience, he has strong technical expertise, which he leverages when working on disputes concerning large, complex multinational projects. 
  • Mark Taylor is a respected name in the market, with over two decades of experience providing damages analysis and financial advice in complex investigations and arbitrations. 
  • Travis Taylor enjoys a spectacular reputation in the forensic accounting field. He is adept at handling fraud investigations and seamlessly dispenses expert opinions from the witness box. 
Germany 
  • Alexander Demuth is a well-regarded expert with deep expertise in quantifying damages in complex international disputes, including post-M&A, investor-state and commercial claims arising from the automotive, energy and pharmaceutical industries. 
Singapore 
  • Chaitanya Arora brings extensive experience providing quantum valuations in expert witness roles. His work in assessing damages issues positions him as a leading figure in the disputes landscape across Asia. 
USA 
  • Bryan D’Aguiar earns plaudits for his “deep technical expertise, impressive quantum analysis and in-depth understanding of the funds industry”. He is praised by market sources who “highly recommend him”. 
  • With over 25 years of experience, Don Harvey has acted in some of the most complex and high-profile construction disputes. His meticulous approach and sharp insights have earned him the spot among top-notch expert witnesses in the field. 
  • With three decades of experience, Paul Marcus is widely perceived as a stellar valuation expert thanks to his compelling witness testimony in complex domestic and international construction disputes. 
  • Described as “simply outstanding,” Garrett Rush brings “all of the skills you need in an expert witness” to complex multi-jurisdictional disputes in the real estate, financial services and transport sectors, among others. 
  • Jennifer Vanderhart consistently earns acclaim from market commentators for her exceptional expertise in damage quantification and her deep understanding of employment and IP-related claims. 
  • Mike Allen is also recognized as a Recommended consulting expert in Lexology’s report.  

Future Leaders 

Canada 
  • Eddie Tobis is widely respected for his precision and depth in quantum, delay, and technical analysis. He is sought after by clients for his “meticulous and accurate arguments that are very precise, yet presented in an easily understandable way”. 
USA 
  • Gigi Cantalupo is a rising star, commended for “her ability to digest large volumes of information and get on top of highly complex issues in no time”. Her deep expertise in quantifying damages makes her an asset in highly complex commercial and investment disputes. 
  • Stuart Dekker is a managing director known for clear, expert testimony on damages and valuation in over 50 major international arbitrations. Praised for flawless reports and sharp insights, he advises Fortune 500 firms, governments, and multilateral institutions globally. 

Forensic Accountants 

Global Elite Thought Leaders 

USA
  • A seasoned testifying expert, Peter Resnick is recognized as a world-leading professional in forensic accounting, with more than 30 years of robust experience in forensic accounting, financial consulting, accounting matters, valuations, and fraud investigations. 

Recommended Consulting Experts 

Germany 
  • Alexander Demuth is widely recognised as one of the leading names in forensic accounting and is adept at providing expert testimony in high-stakes arbitration and litigation proceedings. 
USA 
  • Rob Hutchins is a well-established expert in forensic accounting, focusing on a range of financial issues, including breach of contract and fraud allegations. His experience spans various industries, making him a trusted source of guidance for clients seeking highly tailored solutions in complex litigation and financial investigations. 
  • Lexology Index says: Gary Kleinrichert has over 30 years’ experience in forensic accounting, focusing on complex investigations and expert testimony. He has worked on high-profile cases involving fraud, embezzlement, and antitrust violations. 
  • Eric Poer has over 25 years of experience as a forensic accountant across a variety of matters, including in large investigations and disputes. Our market sources describe him as “an amazing expert” and “a go-to for forensic work”. 
  • Edward Westerman is one of the leading forensic accountants in the market with over 25 years of experience in complex international matters concerning white collar crime, regulatory enquiries, and corruption and bribery. 

Shalabh Gupta and Amran Nawaz, Associate Directors in Secretariat’s Global Sports Consulting practice, were recently quoted in an S&P Global article discussing sports team acquisition and valuation trends.

Sports team deal values are reaching record highs in 2025 with no sign of slowing, catalyzed by the growing role of private equity investors in the sports investment landscape. While revenues are steadily increasing, valuations are growing even more rapidly—prompting questions about whether this historic growth is sustainable. In the article, Gupta and Nawaz discuss how strategic operational improvements introduced through PE investments and new ownership models could justify rising sports team valuations beyond traditional revenue metrics.

“We are seeing growing interest from a new profile of investors who view the sports industry as an untapped market with significant potential to provide returns,” Nawaz shares in the article.

Likewise, Gupta states that one particular appeal for investors is the revenue opportunities, which expand beyond team merchandise or traditional media rights. He notes, “…stadiums are increasingly being used for concerts and other sporting events, as clubs look to generate revenue during the [about] 300 days a year when the venue would otherwise sit idle.”

As the influence of private equity investments continues to transform the economics of sports, the definition of winning is shifting—from season records to margins and monetization.

Read the full article here.

Managing Director Tamika Tremaglio was featured in a recent article in The Washington Post explaining the ongoing WNBA collective bargaining agreement negotiations and the “unprecedented leverage” possessed by the league’s players union to explore new financial structures that go beyond revenue sharing, like equity. She added that, thanks to the name, image and likeness (NIL) era of college sports, younger players understand their value more than ever. If negotiations don’t end the way the players want, she said, they may seek unprecedented alternatives.

“Many people with tremendous wealth are asking the question of, ‘Should we start our own league?’” Tamika said. “People are holding their breath [watching these negotiations]. A lot of what’s being thought about is really dependent on what happens in the CBA — not only here in the U.S. but I think globally.”

Read Tamika’s full quotes in The Washington Post here (subscription may be required).

By Norman Harrison and Michael Koenig1

Since the election in November 2024, there have been many changes to DOJ’s enforcement policies. Earlier this year, now-Acting Assistant Attorney General of the Criminal Division, Matthew R. Galeotti, announced at the Securities Industry and Financial Markets Association (SIFMA), that going forward prosecutors and investigators would primarily focus on “the most egregious white-collar crime” to better “incentivize [companies] to come forward, come clean, reform, and cooperate with the government.”[2]

That same day, the Criminal Division released two companion memoranda authored by Galeotti, each signaling significant shifts in white-collar enforcement. The first, titled “Focus, Fairness, and Efficiency in the Fight Against White-Collar Crime”[3] (the Galeotti Enforcement Memorandum), outlines procedural reforms and case resolution standards intended to streamline investigations and strengthen individual accountability. The second, “Selection of Monitors in Criminal Division Matters”[4] (the Galeotti Monitor Memorandum), updates internal guidance for determining when and how DOJ prosecutors should impose corporate compliance monitors, emphasizing proportionality and efficiency.

Together, these memoranda signal a significant effort to harmonize white-collar enforcement practices with the Administration’s priorities while ostensibly reinforcing DOJ’s commitment to its core principles. The new guidance redefines how individual accountability will be pursued, restructures the use of corporate resolution tools, and recalibrates the role that cooperation will play in making charging decisions and determining remedies. As the Galeotti Enforcement Memorandum[5] explains, the revised policies are rooted in three guiding principles:

  • Focus: prioritizing high-impact offenses,
  • Fairness: holding individuals accountable while rewarding compliant companies, and
  • Efficiency: shortening investigations, limiting the use of independent monitors, and reducing costs and collateral impact.

Revised Criminal Division Priorities and Guidelines

The Galeotti Enforcement Memorandum provides that DOJ will target individuals and enterprises that exploit taxpayer-funded programs, such as Medicare, Medicaid, and other health care programs, as well as defense procurement fraud.

Other priority areas include investment fraud, money laundering, and evasion of sanctions and tariffs, all of which are viewed by the Administration as threats to U.S. economic security, competitiveness, or national security.

DOJ will also prioritize digital asset crimes that harm investors or consumers, enable broader criminal schemes, or involve deliberate misuse to fuel significant illegal activity, to “ensure that American businesses are competing on a level playing field in global trade and commerce.”[6]

In pursuit of that goal, DOJ appears to be creating a Market, Government, and Consumer Fraud Unit within the Fraud Section by combining the Market Integrity and Major Fraud Unit with part of the Civil Division’s Consumer Protection Branch. The new unit will focus on, among other things, tariff evasion, making good on the Galeotti memoranda’s commitment to targeting such crimes.

Additionally, the scope of the DOJ’s whistleblower program, which previously covered specific categories of offenses including foreign and domestic corruption, healthcare fraud, and certain financial crimes,[7] has been expanded to include several new categories of criminal offenses, notably: corporate sanctions offenses; trade, tariff, and customs fraud by corporations; and corporate procurement fraud. 

The Galeotti Enforcement Memorandum further updates DOJ’s corporate enforcement policy to ensure that companies that voluntarily self-disclose, fully cooperate, and promptly remediate wrongdoing are less likely to face criminal charges. Even in cases involving allegations of serious wrongdoing, prosecutors may still decline prosecution if a company demonstrates full cooperation and effective remediation. In cases lacking voluntary self-disclosure, or where aggravating factors are present, companies that do not qualify for a full declination may still benefit under the DOJ’s revised enforcement approach. The Criminal Division emphasizes holding individual wrongdoers accountable while encouraging corporate compliance, recognizing that not all corporate misconduct warrants prosecution. The Galeotti Enforcement Memorandum affirms that prosecutors must weigh factors such as disclosure, cooperation, and remediation in determining an appropriate resolution, whether through a non-prosecution agreement, deferred prosecution agreement, or guilty plea.

Revised Approach to Monitor Appointments

The Galeotti Monitor Memorandum updates both the criteria for requiring appointment of an independent monitor and the process by which monitors are selected and overseen.[8] Prosecutors must clearly explain why a monitor is necessary, tailor the scope of monitorship to address the specific risk of recurrence of the crime and never impose a monitor as a punitive gesture. Under the new guidance, in determining the structure and duration of monitorship, DOJ will emphasize proportionality by ensuring costs of the monitorship align with the severity of and profits derived from the misconduct, taking into account the company’s size and risk profile.

If a company is already under robust regulatory oversight that meets DOJ’s compliance goals, a separate monitorship may be unnecessary. The more proactive a company is in addressing misconduct, such as firing wrongdoers, updating internal controls, and improving compliance systems, the more likely it is to avoid or shorten a monitorship.

In line with the DOJ’s new monitorship policy, the Criminal Division recently reviewed ongoing monitorships and took decisive action, demonstrating real-world application of its revised standards. Notably, the department formally announced the early termination of Glencore’s monitorship, previously imposed after its guilty plea for bribery and market manipulation, citing its “sole discretion under the plea agreement” and a careful “assessment of the facts and circumstances.”[9] Albemarle Corporation also announced the early termination of a monitorship earlier this year.[10] These moves align precisely with DOJ’s new guidance that monitor appointments must be justified, tailored, and cost proportionate.

The only pending independent compliance consultant requirement is included in a Non-Prosecution Agreement recently concluded between DOJ and the Boeing Company (which was originally a deferred prosecution agreement that included a requirement to appoint an independent compliance monitor). The matter is still under consideration by a federal district court, so the outcome remains uncertain.

Implications for Companies and the C-Suite

To summarize, companies may now secure more favorable resolutions, reduced penalties and shorter oversight periods by self-reporting, cooperating in good faith in DOJ’s investigations, strengthening compliance and embracing transparency.

In response to the revised guidance, companies should reassess key elements of their risk assessment, compliance policies, and controls. As examples, it may be prudent to:

  • Undertake proactive investigations to identify misconduct and foster a proactive government-reporting culture to capture the benefits of cooperation credit;
  • Ensure that whistleblower policies encourage reporting, protect against retaliation, and are backed by robust internal investigative procedures;
  • Reexamine enterprise risk assessment frameworks, to reflect DOJ’s revised priorities;
  • Ensure that compliance policies, procedures and internal controls – and periodic internal testing protocols – are modified, if necessary to be fully adapted to the revised criminal enforcement regime; and
  • Evaluate the sufficiency of counterparty due diligence tools and practices, to better protect against potential fallout arising from commercial dealings with high-risk entities.

[1] The authors express appreciation to Giya Sahni, an intern in Secretariat’s Global Investigations & Disputes practice, for her assistance in the preparation of this article.
[2] https://www.justice.gov/opa/speech/head-criminal-division-matthew-r-galeotti-delivers-remarks-sifmas-anti-money-laundering
[3] https://www.justice.gov/criminal/media/1400046/dl?inline
[4] https://www.justice.gov/criminal/media/1400036/dl?inline
[5] https://www.justice.gov/criminal/media/1400046/dl?inline
[6] Id., 3
[7] https://www.justice.gov/criminal/criminal-division-corporate-
[9] United States v. Glencore Int’l A.G., No. 22 Cr. 297 (LGS) (S.D.N.Y.)
[10] https://www.sec.gov/ix?doc=/Archives/edgar/data/0000915913/000091591325000084/alb-20250331.htm