Jerome Tomas co-chairs the Firm's SEC and Financial Institutions Enforcement Group. He has been recognized by Chambers in Illinois for White Collar Crime & Government Investigations. He works with clients to investigate and remediate their most serious compliance concerns and to proactively assess and mitigate legal and compliance risk in domestic and global operations. Leading teams of lawyers to address client needs, Jerome provides advice that addresses government law enforcement while being pragmatic and business-oriented, as required for management and boards to compete internationally. He has extensively represented clients in government litigation and enforcement investigations, including before the SEC, the US Department of Justice (DOJ), various US Attorneys Offices and the Commodities Futures Trading Commission (CFTC).
Prior to joining Baker McKenzie, Jerome was a senior attorney in the SEC’s Division of Enforcement, where he worked on several significant and high-profile matters covered in BusinessWeek and Barron's.
Jerome regularly advises multinationals on risk mitigation and compliance in the context of international mergers and acquisitions, other business combinations and general corporate transactions. He has advised on anticorruption and trade compliance in transport, telecommunications, mining, oil and resource extraction, chemical, defense, pharmaceutical, health care, agriculture, technology, hotel, travel, hospitality, consumer products and manufacturing industries. He also advises multinationals on compliance with US and international anti-money laundering laws and the US Bank Secrecy Act.
Jerome also conducts internal investigations and advises clients' management, boards and audit committees on appropriate remedial and strategic matters. He has extensive experience representing clients in investigations, including on US laws in federal securities, commodities, anti-money laundering, wire and mail fraud and potential violations of federal procurement laws, including investigations related to the FCPA, the UK Bribery Act, disclosures, financial statement and auditor issues, insider trading, commodities manipulation, money laundering, and OFAC-related matters.
Representative Legal Matters
Litigation/Investigations/Government Proceedings/Regulatory Matters
- Represented the special committee of a publicly traded consumer products company in conducting an internal investigation and SEC and DOJ investigations into potential FCPA violations in China.
- Represented a non-US, formerly publicly traded commodities company, in an SEC investigation into its restated financial statements.
- Represented a multinational US-based consumer products company in connection with SEC and DOJ investigations into potential violations of US federal securities laws in India, including the FCPA.
- Represented a multinational US-based beverages company in connection with SEC and DOJ investigations into potential violations of the US federal securities laws in India, including the FCPA.
- Represented a multinational telecommunications company in an investigation related to potential data breaches in several jurisdictions.
- Represented a US-based publicly traded company in an internal investigation into the reclassification of expenses and adjustment of reserves in connection with the close of the financial year.
- Represented a foreign private issuer in a technology company investigated by the SEC and DOJ for potential FCPA violations in China. Resulted in a declination of enforcement action.
- Represented a non-US-based logistics company investigated by the SEC and DOJ for potential FCPA violations in multiple jurisdictions. Acted as lead counsel in resolution of SEC enforcement action, resulting in a settlement on favorable terms.
- Represented a US-based public company in connection with an SEC investigation involving potential financial disclosure fraud.
- Represented a non-US financial institution investigated by the SEC for potential violations of US federal securities laws. Resolved SEC enforcement action on favorable terms.
Professional Associations and Memberships
- American Bar Association, ABA Securities Enforcement Committee - Co-chair
- Association of SEC Alumni (ASECA) - Member
- U.S. District Court, Northern District of Illinois~United States (2001)
- Illinois~United States (2001)
- Loyola University Chicago School of Law (J.D. cum laude) (2001)
- Michigan State University (B.A. International Relations) (1996)