HenryKlehm III

Practice Leader Securities Litigation & SEC Enforcement

New York + 1.212.326.3706

Henry Klehm leads the Firm's Securities Litigation & SEC Enforcement Practice. He has more than 30 years of experience in major corporate investigations, civil and criminal enforcement actions, and related litigation throughout the world, including experience as a senior enforcement officer at the U.S. Securities and Exchange Commission (SEC), as a senior in-house lawyer at two global financial institutions, and as a public company director. He counsels boards, corporations, and financial institutions on cross-border internal investigations, crisis management, corporate governance, and effective compliance and ethics programs, as well as legal matters related to internal control, auditing, litigation loss contingencies (ASC 450), and whistleblowers.

Recent representations include public companies, audit and special committees, financial institutions, and senior corporate officers in investigations and litigation involving disclosure, complex financial products, financial reporting, the Foreign Corrupt Practices Act (FCPA), money laundering, and economic sanctions.

Prior to joining Jones Day, Henry was Deutsche Bank's global head of compliance and Prudential Financial's deputy general counsel for regulatory matters. He was with the SEC for 10 years, serving as head of enforcement for the northeastern United States for five years, where he investigated, litigated, and supervised more than 500 enforcement actions including insider trading, financial frauds, Ponzi schemes, rogue traders, market manipulations, and investment company and advisor matters.

Since 2006, Henry has served as an independent director of RenaissanceRe Holdings, an NYSE-listed catastrophe reinsurance firm. He is currently chair of the Compensation and Governance Committee and previously chaired the audit committee.

Henry frequently lectures on cross-border investigations, financial services, and corporate governance matters.


  • FirstEnergy sells $3.5 billion transmission stake to BrookfieldJones Day advised FirstEnergy Corp. in the $3.5 billion sale of an additional 30.0% equity stake in its subsidiary FirstEnergy Transmission (“FET”), the holding company for FirstEnergy’s three regulated electric transmission businesses, to North American Transmission Company II L.P., FirstEnergy’s existing joint venture partner in FET and a controlled investment vehicle entity of Brookfield Infrastructure Partners.
  • Deutsche Bank defeats class certification in interest rate swaps antitrust litigationJones Day client Deutsche Bank prevailed in its efforts to defeat class certification in the In re Interest Rate Swaps Antitrust Litigation matter in the Southern District of New York.
  • Publicly traded non-U.S. real estate investment trust reviews its compliance and ethics programJones Day advised non-U.S. client in connection with a review of compliance and ethics program in Mexico and the United States.
  • National retailer concludes DOJ and SEC FCPA resolutionsJones Day advised a national retailer on compliance with its DOJ and SEC FCPA resolutions, including the terms of its independent DOJ monitorship, compliance program obligations, and self-reporting obligations.
  • FirstEnergy sells $2.4 billion minority transmission stake to BrookfieldJones Day represented FirstEnergy Corp. in its $2.4 billion sale of a 19.9% equity stake in its subsidiary FirstEnergy Transmission, the holding company for FirstEnergy’s three regulated electric transmission businesses.
  • Gordon Coburn defends FCPA case brought by DOJJones Day represents Gordon Coburn, former President of Cognizant Technology, in an FCPA case brought by DOJ in the District of New Jersey.
  • FirstEnergy reaches agreement to resolve Department of Justice investigationJones Day represented FirstEnergy Corp., an Akron, Ohio-based public utility holding company, in connection with negotiating a Deferred Prosecution Agreement ("DPA") with the DOJ to resolve the DOJ's investigation into FirstEnergy.
  • Banco Delta Asia secures withdrawal of Section 311 designationJones Day represented Banco Delta Asia, a small family-owned Macau bank, and its owner in a lawsuit challenging the Financial Crimes Enforcement Network's (FinCEN) 2007 designation of the bank as an institution "of primary money laundering concern" under Section 311 of the USA PATRIOT Act.
  • Chinese financial institution responds to subpoena for records in major U.S. investigationJones Day represented a Chinese financial institution in a matter relating to a significant U.S. government investigation.
  • Financial institution conducts internal investigation of notary and affiant practicesJones Day conducted an internal investigation of notary and affiant practices at a business unit of a major financial institution and advised the client on related disclosures to government agencies.
  • Fortune 500 public company assesses its investigation processes and develops enterprise-wide investigations governance structureJones Day is assisting a Fortune 500 public company in a year-long project to assess its investigation processes and develop a new, enterprise-wide investigations governance structure.
  • Former CEO of multinational metals and mining corporation represented in SEC investigationJones Day is representing the Former CEO of Rio Tinto, a multinational mining company, in the Southern District of New York in a 10b-5 securities fraud case brought by the SEC.
  • Citizens Financial Group secures dismissals of putative class action claimsJones Day client Citizens Financial Group Inc. (“Citizens”) secured dismissals of putative class action complaints brought by two shareholders who claim that Citizens violated the Securities Exchange Act of 1934 by making alleged misstatements regarding the extent to which customer appointments were made or kept.
  • The Port Authority of New York & New Jersey obtains highly favorable settlement with SECJones Day client The Port Authority of New York & New Jersey obtained a highly favorable settlement with the SEC in an investigation of the Port Authority's funding of $1.8 billion in New Jersey Roadway Projects.
  • Deutsche Bank resolves class action lawsuit over allegations of conspiracy to stifle competition in CDS marketJones Day client Deutsche Bank AG, New York achieved a settlement agreement in an antitrust class action brought by an Ohio union pension plan claiming that Deutsche Bank and other bank defendants conspired to prevent the development of credit default swap ("CDS") exchange trading and CDS futures products in an effort to stifle competition in the CDS market, in turn allegedly raising fund managers' costs.
  • One Equity Partners acquires All Metro Health CareJones Day represented One Equity Partners LLC in connection with its acquisition of All Metro Health Care, a provider of in home care services.
  • SFW Capital Partners makes strategic investment in Gerson Lehrman GroupJones Day represented SFW Capital Partners in connection with its $212 million strategic investment in Gerson Lehrman Group, Inc., a leading global platform for professional learning.
  • Jones Day advises on UK's first Deferred Prosecution Agreement and closure of U.S. DOJ investigationOn Monday, November 30, 2015, the Right Honourable Sir Brian Leveson (the President of the Queen's Bench Division) approved the resolution of the first UK Bribery Act section 7 proceedings by way of a Deferred Prosecution Agreement, a procedure never before used in the UK.
  • Uprising Management forms Uprising Investors Fund I, L.P. and Uprising Investors Opportunity Fund I, L.P.Jones Day represented Uprising Management LLC in connection with the formation of Uprising Investors Fund I, L.P. and Uprising Investors Opportunity Fund I, L.P., a venture capital fund.
  • City National Bank of Florida acquired by Banco de Credito e Inversiones for $946.9 millionJones Day advised certain members of senior management of City National Bank of Florida in connection with the acquisition by Chile's Banco de Credito e Inversiones for $946.9 million.
    • June 13, 2019
      2019 German Client Conference: New Challenges Crossing Borders
    • October 20, 2016
      PLI's Broker/Dealer Regulation and Enforcement 2016
    • October 22, 2015
      Current Issues in Securities Enforcement, panelist, PLI Broker-Dealer Regulation and Enforcement
    • September 15, 2015
      Executive Roundtable Series - Opportunities and Risks in the International Marketplace: Developments and Trends in International Trade, Export Controls, and Global Cybersecurity
    • May 15, 2015
      Ethics for Financial Services Lawyers: What In-House Counsel Need to Know, Financial Services Roundtable, Lawyers Council Spring Meeting
    • April 30, 2015
      Institute of International Bankers Annual Anti-Money Laundering Seminar, Practical Suggestions for Effective BSA/AML Compliance Programs
    • Various
      Cross Border Internal Investigations and Crisis Management, guest lecturer, Fordham University School of Law
    • February 9, 2015
      Current Issues in Corporate Compliance Programs, panelist, Fordham University School of Law Corporate Compliance and Corporate Governance Symposium
    • December 10-11, 2014
      Brazilian Companies and the U.S. Foreign Corrupt Practices Act: Exploring the Reach of the FCPA
    • June 13, 2014
      2014 Speaker Series: When Complaints Reach the Board: Bench and Bar Perspectives on Internal Corporate Investigations, the Use of Special Committees, and Judicial Oversight of Board Investigations
    • April 25, 2014
      Corporate Crisis Management, panelist, ABA Sixth Annual Insitute on Internal Investigations and Forum for In-House Counsel
    • April 1, 2014
      Antimoney Laundering Developments, panelist, 2014 SIFMA Compliance & Legal Annual Seminar
    • October 24, 2012
      PLI’s Broker/Dealer Regulation and Enforcement 2012
    • February 2, 2012
      Globalization of Anti-Corruption Enforcement: Russia
    • October 26, 2011
      PLI’s Broker/Dealer Regulation and Enforcement 2011
    • August 11, 2011
      The Dodd Frank P.S.: Living with Whistleblowers in a New Era of SEC Enforcement
    • August 7, 2011
      Will There Be Mutiny on the Bounty? The Risks of the Dodd Frank Whistleblower Provisions for Global Business, American Bar Association
    • June 30, 2011
      Managing Your Risk - Bribery, Corruption and Business Ethics
    • May 19, 2011
      Jones Day MCLE University - Chicago
    • May 2011
      Managing your Risk - Bribery, Corruption and Business Ethics
    • March 31, 2011
      Regulation and Enforcement of Broker-Dealers & Investment Advisers, American Conference Institute
    • October 27, 2010
      PLI’s Broker/Dealer Regulation and Enforcement 2010
    • April 22, 2010
      Enterprise Risk Management, 2010 Speaker Series
    • March 25, 2010
      Knowing, Managing, and Measuring your Corporate Compliance Risks and Needs - Dallas
    • March 24, 2010
      Knowing, Managing, and Measuring your Corporate Compliance Risks and Needs - Houston
    • June 2009
      Recent Developments in U.K. Anti-Corruption Law
    • October 29, 2008
      Coping with Broker/Dealer Regulation and Enforcement
    • June 10, 2008
      Dealing with the Government, panelist, Practising Law Institute, Internal Investigations 2008: Legal, Ethical & Strategic Issues
    • June 10, 2008
      Internal Investigations 2008: Legal, Ethical & Strategic Issues
    • April 16, 2008
      Conducting Cross-Border FCPA Investigations, moderator, Global Anti-Corruption Compliance & Ethics Conference