Arthur B. Culvahouse, Jr. is a partner in the Washington, DC office of O’Melveny & Myers LLP, and has an active corporate governance, internal investigations, compliance and strategic counseling practice.
Mr. Culvahouse served as Chair of the Firm from 2000 to early 2012. He has practiced law with O’Melveny from 1976 to 1984, and from 1989 to the present.
From March 1987 through January 1989, Mr. Culvahouse served as Counsel to the President of the United States. As White House Counsel, Mr. Culvahouse advised President Ronald Reagan on matters ranging from the Iran-Contra investigations, to the Supreme Court nominations of Robert Bork and Anthony Kennedy, to the legal aspects of the Intermediate-range Nuclear Forces Treaty; and he chaired the inter-agency lawyers Committee on War Powers and the President’s Committee on Federal Judicial Nominations. In January 1989, President Reagan awarded Mr. Culvahouse the Presidential Citizens’ Medal, an award established in 1969 to “recognize citizens who performed exemplary deeds of service for the country or their fellow citizens.”
From June 1973 until November 1976, Mr. Culvahouse was Chief Legislative Assistant and Counsel to US Senator Howard H. Baker, Jr.
From 1990 through 1992, Mr. Culvahouse served as a member of the Federal Advisory Committee on Nuclear Failsafe and Risk Reduction, appointed by the Secretary of Defense, to evaluate and recommend improvements in the United States Nuclear Command and Control System. In December of 1992, Secretary of Defense Cheney awarded Mr. Culvahouse the Defense Medal for Distinguished Public Service. Mr. Culvahouse’s prior service on boards and commissions includes service on The President’s Foreign Intelligence Advisory Board and the Intelligence Oversight Board (2006-2009); the Nuclear Command and Control System Federal Advisory Committee, appointed by the Secretary of Defense (2008-2009); the US Chamber of Commerce Commission on the Regulation of US Capital Markets in the 21st Century (2006-2007); the Board of Directors of the Leadership Council on Legal Diversity (2009-2012); the Supreme Court Fellows Commission (2002-2005); the Board of Visitors of the US Naval Academy (1989-1991); and the Counterintelligence Advisory Panel to the US Senate Select Committee on Intelligence (1989-1990).
Mr. Culvahouse’s board level counseling and investigative experience includes:
1. Government Commissions:
As member of both President’s Foreign Intelligence Advisory Board and President’s Intelligence Oversight Board (2006-2009), participated in high level “audit” of implementation by U.S. Intelligence Community of the recommendations of the 9/11 Commission and the WMD Commission
Member of two Secretary of Defense-appointed advisory committees on command and control by U.S. of its nuclear weapons
2. Represented Boards of Directors and Board Committees, including:
Independent Directors of large U.S. healthcare company in connection with back-dated stock option grants and related derivative litigation
Audit Committee of large multi-national company with respect to:
(i) monitoring management and company counsel’s compliance with document requests and substantive submissions to competition law authorities
(ii) advising Board on appropriate internal discipline and adjustments to compensation process
(iii) reviewing adequacy of securities disclosures and reserves
(iv) reviewing and commenting on effectiveness of updated compliance program
(v) advising on CEO succession
(vi) responding to shareholder demand letter
Board of Directors of two international energy companies with respect to certain corporate governance matters and with respect to economic sanctions and FCPA compliance
Board of Directors of a U.S. Government-Sponsored Enterprise with respect to potential claims against former senior executive and with respect to derivative litigation involving certain directors
3. Multiple representations involving economic sanctions, anti-bribery laws, and AML, including:
Represented International Olympic Committee and its President in DOJ and Congressional investigations of Salt Lake City Winter Games bribery allegations and with respect to internal controls improvements
Represented U.S. investment bank in structuring its domestic securities joint venture in China and briefing DOJ and SEC with respect to certain economic contributions required by the PRC government
Represented U.S. energy company with respect to Congressional investigation, and Treasury, State Department, and White House deliberations regarding controversial oil services agreement with Iran (pre-Iran sanctions)
Represented multiple investment banks, oil companies, oil service companies, communications providers, trading companies and would be acquirers with respect to compliance with economic sanctions against Libya, Cuba, Iraq (and Kuwait), Iran, Sudan, etc., including corporate governance and securities disclosures with respect thereto
Represented major trading company in a DOJ criminal investigation of use of letters of credit issued by U.S. bank to facilitate trade with Cuba
Currently lead teams providing AML, FCPA, business in-take, and regulatory compliance advice to investment bank and to multi-national company on regular basis, including conducting internal investigations as required
4. Other notable representations include:
Represented former Chairman of the Federal Reserve System Board of Governors in inquiry by the Financial Crisis Inquiry Commission (“FCIC”)
Represented Chairman of the Board of Directors of the Federal Reserve Bank of New York in inquiries by a Congressional Committee and FCIC
Represented Securities and Exchange Commission Chairman Arthur Levitt in confirmation matters and in U.S. Congressional inquiry into alleged non-compliance with business travel expense requirements
Represented major automobile manufacturer in congressional and NHTSA investigations of SUV roll-overs connected to tire failures
Represented medical device manufacturer in criminal inquiry of breast implants
Advised U.S. sellers and/or foreign purchasers in transactions subject to review under Exon-Florio Act
Mr. Culvahouse serves as a member of the Board of Trustees of The Brookings Institution, the Leadership Board of the Center for Capital Markets Competitiveness, established by the US Chamber of Commerce, and the Board of the Howard H. Baker, Jr. Center for Public Policy at the University of Tennessee.
Mr. Culvahouse received his J.D. from New York University and earned his B.S. from the University of Tennessee. Mr. Culvahouse is admitted to practice in the District of Columbia, California (inactive), New York, Tennessee, and the U.S. Supreme Court. Mr. Culvahouse was born on July 4, 1948, and is a native of Ten Mile, Tennessee.
