Cheryl Scarboro, formerly an Associate Director in the SEC’s Division of Enforcement and the first Chief of the SEC’s FCPA Unit, is a Partner in the Washington, D.C. office of Simpson Thacher & Bartlett LLP and a member of the Firm’s Government and Internal Investigations Practice. She represents corporations, financial institutions and individuals in government investigations and other regulatory enforcement proceedings. Cheryl handles sensitive internal investigations on behalf of management, boards and special committees, and routinely counsels clients on compliance programs, SEC reporting, disclosure and corporate governance requirements.
Cheryl’s selected representations include:
- A telecommunications company in SEC FCPA investigation
- A former employee of a mining company in an action brought by the SEC alleging accounting violations relating to the value of a project in Africa
- Special Litigation Committee of a Fortune 50 company in an internal investigation related to the Company’s handling of allegations of sexual harassment
- Various senior executives in connection with SEC/DOJ investigations into potential FCPA violations
- Large Asian company in connection with SEC investigation of potential FCPA violations
Cheryl joined the Firm following a 19-year tenure at the SEC, where she led significant investigations involving a broad variety of subjects, including alleged violations of the FCPA, the Investment Advisers Act, issuer accounting fraud and other disclosure violations, market manipulation, broker-dealer misconduct and insider trading. As head of the SEC’s FCPA practice, Cheryl played a role in all of the SEC’s recent major FCPA cases and acted as the SEC liaison with the DOJ and regulators around the world.
Chambers USA Nationwide and Chambers Global consistently recognize Cheryl as a leading individual in FCPA. She has been recognized as one of the “25 Most Influential Women in Securities Law” by Law360, and one of the “Top 10 Women in Litigation” by Benchmark Litigation. Cheryl is consistently listed in the “Top 250 Women in Litigation” by Benchmark Litigation, where market commentators describe her as “an internal investigations luminary” with a “huge place in the FCPA world.” She was recently recognized as part of Corporate Counsel’s “Women, Influence & Power in Law Awards” and named to Global Investigations Review’s “Women in Investigations” and “The Top FCPA Practitioners” 2021 lists, with the profile highlighting that, “few lawyers, if any, can match [Cheryl’s] credentials.” Cheryl was also named to Savoy Magazine’s 2022 and 2018 “Most Influential Black Lawyers” lists. In addition, she was named to the “Enforcement 40” by the Securities Enforcement Forum, is consistently recommended by The Legal 500 in white collar and was named a National and Washington, D.C. “Litigation Star” by Euromoney’s Benchmark Litigation in white collar.
Cheryl earned her J.D. from Duke University School of Law in 1989 and her B.A. from University of Alabama in Huntsville in 1986.
Updated July 2023
