Trending Topics
Introduction
Christopher Hotaling is a member of the Government Investigations & White Collar Defense practice group. After 16 years as a federal prosecutor at the U.S. Attorney’s Office in Chicago, Chris focuses his practice on representing entities and individuals in all types of government investigations, criminal prosecutions, and regulatory enforcement actions. A seasoned trial attorney with dozens of jury trials under his belt, clients also come to Chris for their most significant complex commercial litigation.
My focus
Government and Internal Investigations and Compliance
Leveraging my years of experience as a federal prosecutor in Chicago, I represent companies, boards of directors, and individuals in internal investigations or enforcement actions brought by the Department of Justice, United States Attorneys’ Offices, the Securities and Exchange Commission, the Department of the Treasury’s Office of Foreign Assets Control (OFAC), federal inspectors general, and other regulatory and enforcement agencies. I also have significant experience investigating and litigating an expansive array of white collar and regulatory areas including securities fraud, bankruptcy fraud, healthcare fraud and the False Claims Act, tax fraud, money laundering, RICO, asset forfeiture, and public corruption. My time in government has provided me with a unique perspective when assisting my clients with government investigations and regulatory matters, including subpoenas issued by federal or state agencies, internal corporate investigations, and criminal and civil enforcement proceedings.
A portion of my practice also focuses on assisting and counseling clients (both domestic and international) to navigate the complexities that often arise in cross-border transactions. I have advised international clients who have come into contact with U.S.-based law enforcement and, in other circumstances, have assisted companies with ensuring their compliance with cross-border laws and regulations, including with respect to Foreign Corrupt Practices Act (FCPA), anti-money laundering (AML) and Bank Secrecy Act, OFAC, and export control compliance. I’m well positioned to help my clients not only ensure their regulatory compliance systems are adequate, but also advise and negotiate on their behalf if they find themselves the target of an investigation. Similarly, I have represented international clients in efforts to secure discovery located in the United States, which is needed in foreign litigation, through the Section 1782 process.
Before joining the firm, I was the Chief of the Narcotics and Money Laundering Section at the U.S. Attorney’s Office for the Northern District of Illinois in Chicago. During my tenure as section chief, I personally led or supervised over 500 complex investigations touching on virtually every corner of federal criminal law. Additionally, while acting as section chief, I served as both the office’s asset forfeiture coordinator and district opioid coordinator. I also have extensive courtroom experience, including 24 federal jury trials, many involving complex fraud and financial issues, and arguments in over 12 matters before the U.S. Court of Appeals for the Seventh Circuit.
Collegiate Sports Experience
I have also recently expanded my practice to include the dynamic and ever-changing world of college athletics. I have represented multiple college coaches in infractions proceedings before the NCAA Committee on Infractions or the Independent Resolution Panel. I can also assist institutions and athletic conferences with compliance reviews, advice regarding the evolving issue of “name, image, and likeness,” litigation brought against an institution or its employees, and other challenges facing collegiate athletics departments.
Representative experience
- Successfully represented NCAA Division I head men’s basketball coach charged with recruiting and head coach control violations. The client was cleared of all allegations at the conclusion of an infractions hearing before the NCAA Independent Resolution Panel.
- Currently representing a different Division I head men’s basketball coach charged with recruiting and head coach control violations.
- Currently representing multiple public utility employees called as witnesses in public corruption trial in Chicago.
- Successfully represented a foreign bank in proceeding before OFAC. After conducting an internal investigation, a voluntary self-disclosure was made. OFAC dismissed the matter with no public disclosure or fine, ending the matter with a cautionary letter to the client.
- Successfully represented client in a market manipulation (“spoofing”) investigation conducted by the DOJ Fraud Division and secured a non-prosecution agreement.
- Successfully represented client in fraud investigation conducted by the DOJ Money Laundering and Asset Recovery Section. The matter was closed with no charges being filed.
- Represented client charged with Paycheck Protection Program (PPP) fraud in the U.S. District Court in Arizona and secured a sentence of probation.
- Currently representing company and its owners/managers in tax fraud investigation in the U.S. District Court in central Illinois. The U.S. Attorney’s Office declined to prosecute the company and its principal owner. After negotiating with the DOJ Tax Division, the primary manager was charged with misdemeanor, instead of felony, counts of tax fraud.
- Currently representing business owner charged with tax fraud and conspiracy in the U.S. District Court in Nevada.
- Currently representing clients in a criminal asset forfeiture proceeding pending in the U.S. District Court in Colorado.
- Currently representing cannabis company in litigation and enforcement proceedings before local prosecutor’s office in northern Illinois.
- Successfully represented rehabilitation clinical practice named as a defendant in a False Claims Act complaint.
- Currently representing client in Bivens action in the U.S. District Court in Philadelphia. For this same client, we have filed multiple Freedom of Information Act (FOIA) civil complaints against the government in the U.S. District Court in Washington DC.
- Successfully represented local mayor and city council members named as defendants in employment suit brought by another city employee in the Circuit Court of Cook County. The judge granted our motion to dismiss.
- Currently representing commercial real estate company in multi-jurisdictional trade secrets and tortious interference case.
- Currently representing medical waste company in a patent infringement and false advertising case in the U.S. District Court in Chicago.
- Represented foreign government in Section 1782 action filed in U.S. District Court in Chicago seeking discovery for use in foreign criminal investigation.
- Represented foreign company in Section 1782 action filed in U.S. District Court in Miami seeking discovery for use in a foreign civil case.
- Drafted anti-money laundering, Bank Secrecy Act, and anti-corruption compliance policies for environmental company.
- Served as temporary chief compliance officer/Bank Secrecy Act officer for a law firm trust company.
Looking ahead
With the recent cooperation policies announced by DOJ, it is now more important than ever to quickly and critically investigate and evaluate a company’s potential exposure and decide whether or not to self-disclose any violations to the government. It is not always the case that self-disclosure is the right course of action.
In the news
- ABC 7 Chicago News
Why were potential jurors dismissed from Madigan trial?
Oct 9, 2024Chicago Government Investigations & White-Collar Defense partner Chris Hotaling joins this broadcast to discuss the start of the Michael Madigan trial. Chris provides procedural insights on how the jury selection process works and what each side may be looking for as the jury composition comes together, as well as the probable timing for the next steps in the trial.
- Law360
Bribery ruling could disrupt ComEd verdict, Madigan trial
June 26, 2024Chicago Government Investigations & White-Collar Defense partner Chris Hotaling is quoted in this article discussing how a US Supreme Court ruling Wednesday that narrows a federal bribery law could impact two prominent Chicago cases, as well as other corruption cases moving forward.
- Bloomberg Law
Federal tool against local corruption faces Supreme Court test
April 13, 2024This article covers an appeal the Supreme Court is hearing today that could substantially limit the federal programs bribery statute, a go-to tool for US prosecutors targeting corruption by state and local public officials. Chicago Government Investigations & White-Collar Defense partner Chris Hotaling is quoted in the coverage, discussing how this statute has been a particularly important anti-corruption statute in jurisdictions like the Northern District of Illinois, where federal prosecutors tend to focus on local corruption.
- Law360
Illinois cases to watch in 2024
Jan 1, 2024The following broadcast news segment features commentary from Chicago Government Investigations and White-Collar Defense partner Chris Hotaling on the guilty verdict reached in the trial of former Chicago Alderman Ed Burke in the “ComEd Four” bribery case. Chris is also quoted in the Law360 article, discussing what to expect when former Illinois House Speaker Mike Madigan goes to trial in April in connection with the case.
- ABC 7 Chicago
Jury finds Ed Burke guilty on multiple counts
Dec 21, 2023The following broadcast news segment features commentary from Chicago Government Investigations and White-Collar Defense partner Chris Hotaling on the guilty verdict reached in the trial of former Chicago Alderman Ed Burke in the “ComEd Four” bribery case. Chris is also quoted in the Law360 article, discussing what to expect when former Illinois House Speaker Mike Madigan goes to trial in April in connection with the case.
- ABC News
He says the US government is ‘hell-bent’ on taking what’s left
Dec 20, 2023This article featuring an interview with Julian Rudolph, whose father murdered his mother in 2016, covers an ongoing dispute related to insurance policy proceeds and other assets seized by the Justice Department. Chicago partner Chris Hotaling and Washington DC partner John Sandweg, both of the Government Investigations & White-Collar Defense practice, are mentioned for representing Julian and his sister, AnaBianca, in seeking to recover proceeds and assets.
- ABC 7 Chicago
Jury gets case in trial of former Alderman Ed Burke
Dec 18, 2023Chicago Government Investigations & White-Collar Defense partner Chris Hotaling joined a discussion on the federal corruption trial of former Chicago Alderman Ed Burke to share commentary on the judge’s 300-plus pages of jury instructions and the government’s use of Burke’s own word in laying out their case.
- Law360
‘Corruption superspreader’ can’t cut jail time, Seventh Circuit says
July 28, 2023Chicago Government Investigations & White-Collar Defense partner Chris Hotaling is quoted in this article covering the Seventh Circuit upholding the five-year prison sentence in former Illinois state representative Luis Arroyo’s bribery case. Chris analyzes Arroyo’s argument that his sentence would be ineffective in deterring other politicians from committing similar crimes, and explains why a Seventh Circuit reversal was unlikely.
- Bloomberg Law
ComEd defendants denied bid to interview jurors after verdicts
May 23, 2023Chicago Government Investigations & White-Collar Defense partner Chris Hotaling provides third-party comments in this article on a judge denying a request by counsel for two former Commonwealth Edison executives—convicted in the “ComEd Four” bribery trial—to interview jurors following the trial. Chris discusses why he believes the judge made the right decision.
- Law360
Madigan trial looms large after ComEd bribery verdicts
May 3, 2023Chicago Government Investigations & White-Collar Defense partner Chris Hotaling provides third-party commentary throughout the following articles, which cover recent guilty verdicts in the “ComEd Four” bribery trial involving former Commonwealth Edison executives and lobbyists.
- Bloomberg Law
‘ComEd Four’ verdicts mean rough day for ex-speaker Madigan
May 3, 2023Chicago Government Investigations & White-Collar Defense partner Chris Hotaling provides third-party commentary throughout the following articles, which cover recent guilty verdicts in the “ComEd Four” bribery trial involving former Commonwealth Edison executives and lobbyists.
- Law360
How feds closed in on Illinois speaker in corruption probe
Chicago Government Investigations & White-Collar Defense partner Chris Hotaling is quoted throughout this article that looks at how prosecutors are approaching racketeering charges against former Illinois House Speaker Mike Madigan.March 4, 2022 - The Banking Law Journal
Whistleblower-initiated FCA investigation highlights risks to PPP borrowers, other pandemic relief beneficiaries
A cross-practice team contributed this article covering the first False Claims Act settlement over Paycheck Protection Program funds that arose from a whistleblower complaint, and it offers insight on the implications of this action for other beneficiaries of coronavirus relief. The NP team comprises Government Investigations & White-Collar Defense practice group leader and Manchester partner David Vicinanzo; Washington, DC partner Adam Tarosky, and Chicago partner Christopher Hotaling, both of the GIWC group; Boston Complex Commercial Disputes partner Morgan Nighan; and New York Financial Restructuring & Bankruptcy partner Robert Christmas.Dec 13, 2021 - Modern Healthcare
Healthcare fraud probes grow in number, intensity
Chicago Government Investigations & White Collar Defense partner Chis Hotaling is quoted in this article for his outlook on the financial incentive that may be driving larger information requests by government investigators.Oct 3, 2020 - Law360
Indicted Flynn Associate Wants To Weigh In On DOJ Dismissal
This article mentions Chicago Government Investigations & White Collar Defense partner Chris Hotaling and Washington, D.C. Complex Commercial Disputes associate Scott Dinner for representing Ekim Alptekin, who on Friday requested permission to file an amicus brief in support of the U.S. Department of Justice's bid in U.S. v. Flynn.June 5, 2020 - Corporate Compliance Insights
Managing Risks That Come with Federal Funds
April 17, 2020NP’s Christopher Hotaling, Adam Tarosky, Scott O’Connell and Colin Missett authored this article detailing key considerations for businesses to consider, given that funds under the CARES Act come with associated responsibilities for recipients, creating potential criminal and civil liability if not properly handled.
- Reuters Legal
Career tracker: Lawyers on the move
This article highlighting personnel moves in the legal space mentions the additions of Washington DC Intellectual Property partner Evan Langdon and Chicago Government Investigations & White Collar Defense partner Chris Hotaling, who joined Nixon Peabody last week.Oct 1, 2019 - Law360
Nixon Peabody nabs Adduci Mastriani IP pro in DC
This article highlighting personnel moves in the legal space mentions the additions of Washington DC Intellectual Property partner Evan Langdon and Chicago Government Investigations & White Collar Defense partner Chris Hotaling, who joined Nixon Peabody last week.Sep 30, 2019 - World Trademark Review
News digest: On the move
This article highlighting personnel moves in the legal space mentions the additions of Washington DC Intellectual Property partner Evan Langdon and Chicago Government Investigations & White Collar Defense partner Chris Hotaling, who joined Nixon Peabody last week.Sep 27, 2019 - Chicago Daily Law Bulletin
Nixon Peabody’s white-collar team adds former prosecutor
This coverage highlights the arrival of Chicago Government Investigations and White Collar Defense partner Chris Hotaling to Nixon Peabody following his tenure with the U.S. Attorney’s Office for the Northern District of Illinois.Sep 25, 2019 - Law360
Nixon Peabody adds ex-prosecutor as partner in Chicago
This coverage highlights the arrival of Chicago Government Investigations and White Collar Defense partner Chris Hotaling to Nixon Peabody following his tenure with the U.S. Attorney’s Office for the Northern District of Illinois.Sep 25, 2019
Admitted to practice
Illinois
U.S. Court of Appeals, Seventh Circuit
U.S. Court of Appeals, Ninth Circuit
U.S. District Court, Northern District of Illinois
U.S. District Court, Central District of Illinois
U.S. District Court, Southern District of Illinois
U.S. District Court, District of Colorado
Education
University of Virginia School of Law, J.D.
Duke University, A.B., cum laude
Professional activities
- Chicago Bar Association, Criminal Law Committee (former chairperson)
- Federal Bar Association
- Sports Lawyers Association
Recognition
- Selected, through a peer-review survey, for inclusion in The Best Lawyers in America® in the field of Criminal Defense: White-Collar Law (2025); listed in Best Lawyers since 2023
- Chicago Crime Commission Stars of Distinction Award for Law Enforcement Excellence (2016)
- OCDETF Strike Force Appreciation Award (2015)
- Executive Office for the U.S. Attorney’s Director’s Award for Superior Performance by a Litigative Team (2010)
Insights And Happenings
View AllProfessionals in the Practice Area
View AllRobert Fisher
Partner / Practice Group Leader, Government Investigations & White Collar Defense- Boston
- Office:+1 617.345.1335
- rfisher@nixonpeabody.com
-
Hannah Bornstein
Partner / Deputy Practice Group Leader, Government Investigations & White Collar Defense- Boston
- Office:+1 617.345.1217
- hbornstein@nixonpeabody.com
-
