Thomas Zeno has more than 25 years of experience in the US Attorney’s Office for the District of Columbia. During that time, Tom investigated and prosecuted economic crimes involving healthcare, financial institutions, credit cards, computers, identity theft and copyrighted materials. In addition, Tom served as the Executive Assistant US Attorney for Operations, where he helped supervise the criminal division of the office.
As the office’s Healthcare Fraud Coordinator for eight years, Tom supervised investigation strategies of agents from the Federal Bureau of Investigation, the Department of Health and Human Services, the Drug Enforcement Administration and the Medicaid Fraud Control Unit regarding healthcare offenses. He also served as the liaison with the office’s civil division on joint proceedings.
Tom’s significant prosecutions include the conviction of five codefendants accused of defrauding an integrated managed care consortium and the criminal portion of a global settlement by a pharmaceutical company for off-label marketing. Tom also has been involved in highly publicized matters including hearings related to the conditions of release for John Hinckley, Jr., attempted presidential assassin, and the criminal tax prosecution of former District of Columbia Mayor Marion Barry.
Tom represents companies, financial institutions, audit committees, medical providers and individuals by conducting internal investigations and defending against government investigations under the False Claims Act (qui tam), sanctions enforced by the Office of Foreign Assets Control (OFAC) and the Foreign Corrupt Practices Act (FCPA).
Tom evaluates these actions through the lens of his extensive experience both as a supervisor as well as a line attorney who handled investigations personally by litigating scores of trials and contested hearings. His insight and judgment make him a powerful advocate when explaining flaws in qui tam or FCPA actions to investigators from the government such as the Department of Justice and Office of the Inspector General.
Tom is the recipient of several commendations and special achievement awards given by the Department of Justice and was awarded Investigation of the Year, Honorable Mention by the National Healthcare Anti-Fraud Association. Tom received the Harold J. Sullivan Award, the highest award presented annually by the Assistant United States Attorneys’ Association for career excellence. He also was awarded the Inspector General’s Integrity Award from the Department of Health and Human Services for his outstanding contributions in healthcare fraud investigations.
Tom is co-editor of the book and co-author of two chapters in Global Business Fraud and the Law: Preventing and Remedying Fraud and Corruption. Published by PLI, the book presents a comprehensive and practical guide to preventing business fraud and corruption, and remedying unlawful behavior should it occur.
Tom is a member of the American Health Lawyers Association and was co-author of “Preserving the Attorney-Client Privilege for In-House Counsel,” published in Connections, the American Health Lawyers Association magazine.
Tom is the co-author of “Uncle Sam Becomes a Doctor: Government Challenges to Medical Necessity,” published in the Bar Journal of the Cleveland Metropolitan Bar Association, and “Rx for Health Care Fraud: The Feds Get Personal,” published in Criminal Justice by the American Bar Association, as well as articles on preventing and responding to data breaches published in Title News and online in Baseline Magazine.
Tom was a panelist analyzing the need for data security by organizations at the 28th Annual Corporate Law Center Symposium presented by the University of Cincinnati College of Law.
Tom served as a panelist for the 19th Sentencing Guidelines Seminar presented by the National Association of Criminal Defense Lawyers and the American Bar Association. He also authored “A Prosecutor’s View of the Sentencing Guidelines,” published in Federal Probation. As an adjunct professor at Georgetown University for eight years, Tom instructed student prosecutors in trial skills at the Criminal Justice Clinic.
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