A counsel in the Litigation Department, Sean Sandoloski’s practice is focused on internal and government-facing investigations, criminal and regulatory enforcement defense, Congressional matters, and issues and appeals involving antitrust and complex commercial litigation. Sean regularly counsels clients facing investigation across the full spectrum of federal, state, and foreign authorities, with a focus on providing holistic solutions to clients' complex problems. Drawing on his past government experience as a White House lawyer and an appellate attorney in the U.S. Department of Justice, Sean's multidisciplinary approach enables him to successfully tackle high-stakes, fast-moving issues, and to advise clients on strategic and regulatory matters—including those with a significant political valence.
From 2018 to 2021, Sean served as Special Assistant and Associate Counsel to the President in the Office of White House Counsel, where he advised the Executive Branch on a range of matters, including Executive Orders and litigation and policy initiatives, and worked closely with officials from a variety of federal agencies and various congressional committees. From 2015 to 2018, Sean served in the Department of Justice as both Senior Counsel in the Office of Legal Policy and in the Appellate Section of the Antitrust Division. In the latter role, representing the United States in the courts of appeals and advising Division leadership on criminal enforcement, civil enforcement, and complex issues of federal and international law.
Experience
- Assistant Attorney General’s Award (2017)
Sean has frequently spoken at various forums addressing trends and developments in constitutional law, antitrust law, and lawyering in the Executive Branch—including regulatory enforcement. In addition, Sean has authored the following articles:
- Panelist, “Conducting an Effective Internal Investigation and Avoiding Common Pitfalls,” Webinar, October 31, 2024
- Panelist, “Whistleblowers: US Regulatory Trends and Best Practices,” Webinar, July 18, 2024
- Panelist, "Short and Distort: Understanding and Responding to Short-Seller Reports," Webinar, June 20, 2024
- Panelist, “New Russia Sanctions Signal Paradigm Shift,” Webinar, January 11, 2024.
- Panelist, “Investigations in the Age of Artificial Intelligence,” Webinar, December 7, 2023
- Panelist, “Managing Crisis and Preparing for the Unexpected,” Institute of Directors India, October 27, 2023
- Panelist, “Conducting an Effective Internal Investigation and Avoiding Common Pitfalls,” Webinar, October 26, 2023
- Panelist, “Ephemeral Messaging, Tangible Costs: The DOJ, SEC, and CFTC Crackdown on Off-Channel Communications,” Webinar, June 21, 2023
- Panelist, “Private Equity Enforcement Trends,” Webinar, March 2, 2023
- Co-Author, "The SEC and Messaging Apps," the Harvard Law School Forum on Corporate Governance (June 15, 2022).
- Co-Author, “The Monaco Memo: What Could It Mean for Criminal Antitrust Enforcement?,” Competition Policy International (Dec. 12, 2021).
- Co-Author, “The End of Independent Agencies?: Restoring Presidential Control of the Executive Branch,” Federalist Society Review (2021).
- Co-Author, “Re-Examining the Notion that Public Companies Cannot Fight Criminal Charges,” Financier Worldwide (October 2014).
Sean’s experience includes the following representative matters*:
- Led a dual monitorship imposed against a foreign bank by DOJ and the CFTC, overseeing remediation of the bank’s compliance program after violations of the commodities laws.
- Represented the audit committee of an energy company in an internal investigation into short-seller allegations of securities fraud and accounting impropriety, with a rapidly ticking clock prior to filing of its financials.
- Represented a public company in an SEC investigation into allegations of material misrepresentations regarding key performance indicators, stemming from a short-seller report. Obtained a public declination which avoided any enforcement action against the client or its officers and directors.
- Represented a healthcare services company against a novel criminal enforcement action by DOJ's Antitrust Division.
- Represented a power generation company in a fast-moving investigation by state authorities stemming from a significant weather event.
- Developed and executed litigation strategy challenging anticompetitive conduct by several major telecommunications companies in their negotiations with content providers.
- Represented the United States in petitions for review of independent agencies’ actions under the Hobbs Act (including petitions against the Federal Communications Commission, Surface Transportation Board, and Federal Maritime Commission).
- Represented an analytical instrumentation company in DOJ and SEC investigations into potential violations of the FCPA focused on accounting practices and gift-giving in China. No charges were filed by any agency.
- Assisted the DOJ-imposed monitor overseeing the implementation of an anti-bribery and anti-corruption compliance program at a major international tobacco company.
*Sean advised on these matters prior to joining Willkie in 2022.
Credentials
Education
Yale Law School, J.D., Yale Law Journal, Executive Editor, 2011 Stanford University, B.A. (with distinction and honors), 2008
Bar Admissions
Court Admissions
United States Supreme Court United States Court of Appeals, 1st Circuit United States Court of Appeals, 7th Circuit United States Court of Appeals, 11th Circuit United States Court of Appeals, D.C. Circuit United States Court of Appeals, Federal Circuit United States District Court, District of Columbia United States District Court, Western District of Michigan
Clerkships
Steven M. Colloton, United States Court of Appeals, 8th Circuit, 2011 - 2012