John P. Cunningham

Baker & McKenzie LLP


John Cunningham is a partner in the North America Litigation & Government Enforcement Practice Group. Previously, he was a senior trial attorney with the US Department of Justice, where he investigated and prosecuted criminal and employment law matters. Before his tenure with the Justice Department, he practiced white collar criminal defense at a firm in Washington, DC, focusing on money laundering, counterfeiting, espionage, and asset forfeiture cases. He also served as a law clerk to the Honorable Gerald B. Lee in the Eastern District of Virginia and worked as an investigative analyst for the criminal division of the FBI. With the FBI, he prepared fraud, money laundering, and forfeiture matters for consideration by the Department of Justice and received formal commendations from the FBI, Justice Department, and IRS. He was editor-in-chief of the University of Richmond Law Review.

Practice Focus

John concentrates his practice on internal investigations, regulatory and civil enforcement matters, global compliance, and white collar criminal defense. He has extensive experience representing clients in a wide range of matters related to the Foreign Corrupt Practices Act, US money laundering laws, corporate compliance, merger and acquisition due diligence, fraud, asset forfeiture, and attorney-client privilege. Additionally, John designs, develops, and enhances compliance programs for US and multinational companies in harmony with the expectations and requirements of the Department of Justice, Securities and Exchange Commission, and other agencies.

Representative Legal Matters

  • Conducted comprehensive anti-corruption internal investigations for multiple global companies, including a renowned consulting firm, an engineering and infrastructure corporation, an IT services company, a producer of business-to-business goods and services, and several product manufacturers.
  • Performed fulsome FCPA and global anti-corruption risk assessments and compliance program evaluations for multinational corporations in a vast array of industry sectors, including technology, life science, manufacturing, industrial equipment, mobile devices, food services, and consulting.
  • Designed and implemented extensive FCPA and global anti-corruption compliance programs for international technology services, business products, aerospace, private equity, IT, engineering, infrastructure, consulting, public relations, and pharmaceutical companies.
  • Managed anti-money laundering risk evaluations and corresponding compliance program enhancements for several global corporations in various industries, including management and consulting, technology, mobile devices, solar energy, and international hospitality services.
  • Counseled a global financial services provider on risk factors involved in purchasing a multinational affiliate, and conducted extensive related pre- and post-acquisition FCPA and anti-money laundering due diligence.
  • Managed complex privilege and investigative components of internal FCPA investigation for a multinational Fortune 100 metals manufacturer.
  • Advised an international information services firm in long-term FBI and SEC fraud and internal controls investigation.
  • Represented individuals in an expansive criminal money laundering matter involving alleged gambling proceeds and a multistate immigration fraud case.

Professional Associations and Memberships

  • District of Columbia Bar - Member
  • Virginia State Bar - Member
  • American Bar Association - Criminal Justice Section - Member
  • Federal Bar Association – Criminal Law Section - Member
  • Association of Certified Anti-Money Laundering Specialists - Member


  • U.S. Supreme Court~United States (2004)
  • U.S. Bankruptcy Court, Eastern District of Virginia~United States (2004)
  • District of Columbia~United States (2002)
  • U.S. District Court, District of Columbia~United States (2002)
  • U.S. District Court, Eastern District of Virginia~United States (2000)
  • Virginia~United States (1999)
  • U.S. Court of Appeals, Fourth Circuit~United States (1999)


  • George Washington University (M.A. American Legal History highest honors) (2008)
  • University of Richmond School of Law (J.D. cum laude) (1999)
  • College of William and Mary (B.A. International Relations) (1991)


  • English


Co-author, "Localising a Global Compliance Programme," Risk & Compliance Magazine, Financier Worldwide Ltd., Jan-Mar 2018 Issue, January 2018

Quoted in, "Travel & Entertainment Corruption Risks: Exploring Compliance Best Practices" (Three-Part Series), The FCPA Report, March-April 2016


Speaker, "5 Essential Elements of Corporate Compliance", October 17, 2018

Panelist, "The FCPA Self-Disclosure Calculus: Measuring the Benefits of US Cooperation Credit with the Associated Risks of Foreign Enforcement, Detention, and Prosecution," American Conference Institute International Conference on the Foreign Corrupt Practices Act, November 2015

Presenter, "Key Steps to Creating a Strong Compliance Culture Through Effective Leadership," Ethisphere, March 2015