Sanjay Bhandari is Co-Chair of the Firm’s White Collar and Investigations Practice. His practice focuses on government investigations, white-collar defense, and intellectual property litigation. He is a former federal prosecutor, a former Securities and Exchange Commission attorney, and an experienced trial lawyer in criminal and civil cases.

Mr. Bhandari has conducted numerous internal investigations, created and reviewed corporate compliance programs, and defended many individuals and corporations in government investigations and enforcement proceedings. He has particular expertise in anti-corruption laws (including the Foreign Corrupt Practices Act (FCPA)), healthcare laws, and securities laws. He has also handled cases involving antitrust, environmental, money laundering, and tax issues, among others.

Mr. Bhandari’s intellectual property experience includes several copyright, patent, and trademark trials, and numerous litigated cases in a wide range of industries, including chemicals, memory chips, medical and dental devices, software, and television broadcasts.

Mr. Bhandari has tried approximately twenty cases before juries, judges, and arbitrators, including trials that ran from a few days to several months in length. The Department of Justice twice recognized his investigative and trial work by awarding him one of its highest awards for federal prosecutors, in 2006 and 2001.

Mr. Bhandari has been named one of The Best Lawyers in America, for Criminal Defense: White-Collar in 2025.

Bar Admissions

• California

Significant Accomplishments
<p>Representative investigations and white collar matters include the following:</p><ul><li>Conducted worldwide investigations into potential FCPA violations at medical device, transportation, and other companies, including in-country investigations in Azerbaijan, Germany, India, Russia, and Turkey.</li><li>Led internal investigation and defense of public healthcare system in Department of Justice False Claims Act matter related to pharmacogenomics testing.</li><li>Represented multiple employees of a U.S. technology company in U.S. and Swiss investigations into violations of U.S. and Swiss anti-corruption laws, securing no U.S. charges, and, together with Swiss counsel, dismissal of Swiss charges.</li><li>Created anti-corruption compliance program for a multinational chemical manufacturer.</li><li>Reviewed and provided recommendations for improvement of the anti-corruption compliance program of a multinational medical device company.</li><li>Represented numerous individuals in internal and government investigations relating to adulteration, anti-kickback, misbranding, off-label promotion, and other FDA and health law issues.</li><li>Conducted pharmaceutical company’s internal investigation into off-label promotion issues in the Western Region.</li><li>Represented numerous individuals and companies in SEC investigations and enforcement actions relating to fraud, insider trading, registration exemption, reserve accounting, and other issues.</li><li>Defense of several individuals in federal and state criminal and civil tax enforcement matters, including active prosecutions in federal and state courts.</li><li>Representation of several individuals in antitrust investigations and prosecutions, including bid-rigging and cartel allegations.</li><li>Defense of a transportation company against charges of criminal violations of California environmental law; charges dismissed.</li></ul><p>Representative intellectual property and business litigation matters include the following:</p><ul><li>Represented a television broadcasting company in copyright and trademark infringement lawsuit through jury trial, resulting in a favorable multimillion-dollar verdict.</li><li>Representation of an electronic design automation company in patent litigation involving semiconductor chip design, including handling infringement, validity, and damages issues.</li><li>Representation of an orthodontic products company in patent litigation involving self-ligating orthodontic brackets.</li><li>Representation of a foreign automotive products manufacturer through arbitration hearing in patent misuse litigation involving rocket science patents.</li><li>Representation of a clothing distributor in contract and intellectual property litigation with customers and business partners.</li><li>Representation of a medical software company in copyright and contract litigation with former business partner.</li><li>Representation of companies and individuals in employee mobility cases involving claims of theft of trade secrets.</li><li>Led civil defense of financier accused of racketeering and fraud, resulting in voluntary dismissal of claims by plaintiff and sanctions against plaintiff’s counsel.</li></ul><p>Mr. Bhandari was in government service from 1999 to 2008, as an Assistant U.S. Attorney in the Southern District of California and an SEC Enforcement Attorney at the SEC’s headquarters in Washington, D.C. Matters he handled included:</p><ul><li><em>United States v. Cunningham</em>: The then-largest bribery and tax evasion case brought against a sitting United States Congressman (Randy “Duke” Cunningham).</li><li><em>United States v. Foggo</em>: The bribery and procurement fraud prosecution of the Executive Director of the Central Intelligence Agency.</li><li><em>United States v. Wilkes</em>: The bribery prosecution of a defense contractor.</li><li><em>United States v. Gardner et al</em>.: The securities fraud prosecutions of numerous executives and business partners of Peregrine Systems, Inc., a San Diego-based business software company that engaged in improper revenue recognition and other irregularities.  Those convicted of fraud included the Chief Executive Officer, the Chief Financial Officer, the Controller, the Worldwide Head of Sales, and many others.</li><li><em>United States v. Fanghella et al</em>.: The fraud and tax evasion prosecutions of numerous executives and business partners of PinnFund USA, Inc., a Carlsbad sub-prime mortgage lender run as a Ponzi scheme (wherein investment funds from new investors were the basis for returns and capital withdrawals paid to old investors).</li></ul>

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• Anti-Corruption Enforcement and Compliance in the Life Science Sector
• FCPA Enforcement in the Pharmaceutical and Medical Device Sectors