Steve Bunnell


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Steve Bunnell, Co-Chair of O’Melveny’s Data Security and Privacy Practice, is a former General Counsel of the US Department of Homeland Security (DHS) and a former Chief of the Criminal Division at the US Attorney’s Office in Washington, DC. Steve’s practice spans many of the most pressing issues facing businesses today, including cybersecurity and privacy, criminal antitrust, healthcare fraud, money laundering and financial institutions fraud, securities fraud, Foreign Corrupt Practices Act, and False Claims Act matters. As the chief legal officer for DHS from 2013 to January 2017, Steve advised senior Department leaders on a wide range of significant legal, policy, and operational issues, including cybersecurity, data privacy, CFIUS, SAFETY Act protection, aviation security, immigration and border security, customs enforcement, government procurement, and the protection of critical infrastructure.

Prior to joining DHS, Steve was the managing partner of O’Melveny’s Washington, DC office, representing corporate and individual clients in a broad variety of complex regulatory, civil and criminal enforcement matters. His practice included representing a major international airline in an international criminal antitrust investigation; conducting internal investigations for health insurance companies in connection with high stakes Medicare and Medicaid fraud allegations; conducting an internal investigation of international corruption allegations for an international development bank; and successfully defending a US financial institution against potential criminal charges for failing to maintain an adequate anti-money laundering program.


Corporate & Government Experience

  • General Counsel, US Department of Homeland Security
  • Chief, Criminal Division, US Attorneys’ Office, Washington, DC
  • Chief, Fraud and Public Corruption Section, US Attorney’s Office, Washington, DC
  • Counsel to the Assistant Attorney General, Criminal Division, US Department of Justice
  • Trial Attorney, Public Integrity Section, Criminal Division, US Department of Justice
  • Assistant US Attorney, US Attorney’s Office, Washington, DC

Honors & Awards

  • Distinguished Public Service Award, United States Coast Guard (2017)
  • Named leading lawyer in International Who’s Who of Business Crime Lawyers (2010-2011)
  • Named “Top Lawyer” by Corporate Counsel (2010-2011)
  • Named to Expert Guides’ handbook of the World’s Leading White Collar Crime Lawyers (2010)
  • Chambers USA (2010-2012, 2020)
  • Best Lawyers in America (2009-2012)


Bar Admissions

  • District of Columbia


  • Stanford University, J.D., 1986: with Distinction; Senior Article Editor, Stanford Law Review; Oehlmann Prize for outstanding legal writing
  • Yale University, B.A, 1982: magna cum laude; Phi Beta Kappa

Professional Activities


  • Honorable Laurence H. Silberman, US Court of Appeals, District of Columbia Circuit

Speaking Engagements

  • Speaker, “National Security and Legal Implications of Blockchain and Cryptocurrencies,” ABA National Security Law Conference (November 2019)
  • Speaker, “Technology Companies' Guide to Data Privacy,” BDO Webinar Series (June 2019)
  • Panelist, “Data Provenance - The Next Frontier,” Global Cyber Innovation Summit (May 2019)
  • Moderator, “National Security, Ransomware And Cyber-Attacks,” Incident Response Forum (April 2019)
  • Keynote Speaker, “CFA Society of New York,” Cybersecurity Conference (April 2019)
  • Panelist, “Cryptocurrencies and Cybercrime: Splintering the Value Chain,” Digital Crimes Consortium Conference (March 2019)
  • Panel on Enforcement with Securities and Exchange Commission Division of Enforcement Cyber Unit Chief, Commodity Futures Trading Commission Director of Enforcement, and Bittrex Chief Strategy Officer, Consensus 2018 (May 2018)
  • “Homeland Security Law and the Private Sector,” ABA 12th Annual Homeland Security Law Institute, Washington, DC (September 2017)
  • “The Role of Lawyers in Cybersecurity,” ABA 12th Annual Homeland Security Law Institute, Washington, DC (September 2017)
  • “The State of Homeland Security and the Rule of Law” The George Washington University Law School, Washington, DC (September 2017)
  • “Regulatory Update & Strategies to Manage Cyber Risk,” Legaltech West 2017, San Francisco, CA (June 2017)
  • “The Justice League: Navigating the Legal Limits of Federal Policy” Panel, University of Chicago Institute (April 2017)
  • Incident Response Forum, Cybersecurity Docket Conference, Washington, DC (April 2017)
  • Cybersecurity for Lawyers, Wilson Center, Washington, DC (September 2016)
  • Cybersecurity and the Lawyer, US Department of Homeland Security training conference for federal lawyers, Washington, DC (June 2016)
  • SIFMA Cyber Law Seminar, Keynote Address, New York NY (June 2016)
  • Privacy and Cybersecurity Roundtable, Washington, DC (April 2016)
  • Introduction to Homeland Security Law, Federal Law Enforcement Training Center, Glynco, Georgia (March 2016, September 2015, and March 2015)
  • ABA Conference on National Security Law, Washington, DC (November 2015)
  • ABA Homeland Security Law Institute, Keynote Address, Washington, DC (August 2015)
  • Oklahoma City Law School, Homeland Security Law Conference, Keynote Address, Oklahoma City, OK (April 2015)
  • ABA Homeland Security Law Institute, Washington, DC (August 2014)
  • Annual Intelligence Law Legal Community Conference, Springfield, VA (May 2014)
  • Corporate Plea Negotiations and Sentencing, National Federal Sentencing Guidelines Conference, Orlando, Florida (May 2011)
  • Hot Topics in Corporate Internal Investigations, DC Bar CLE Presentation, Washington, DC (October 2010)
  • Corporate Plea Negotiations and Sentencing in a Post Thompson Memo World, National Federal Sentencing Guidelines Conference, St. Petersburg, Florida (May 2010)
  • Sentencing Practice and Procedure: Plea Negotiations, Charging Practices, Sentencing Tactics, and Victims Rights, ABA Criminal Justice Section's Fall Program, Washington, DC (November 2009)
  • Assessing and Managing the Risk of US Law Enforcement Actions, O’Melveny/Deloitte Conference on the Re-Regulation of America After the Financial Meltdown: The View of Washington, DC Insiders, Hong Kong (October 2008)
  • Federal Plea Bargaining, Federal Bar Association and United States Sentencing Commission Annual Conference on the Federal Sentencing Guidelines, Orlando, FL (May 2008)
  • Federal Law Enforcement Trends, Association of Corporate Counsel, Southern California Chapter, Los Angeles, CA (February 2008)
  • Law Enforcement Issues in Export Control Investigations, TechNet Export Controls Conference, Santa Clara, CA (January 2008)


  • Co-Author, “Digital deception: Is your business ready for ‘deepfakes’?” Business Insurance (March 2020)
  • Co-Author, “Webinar Recap: Technology Companies’ Guide to Data Privacy,” BDO (July 2019)
  • Co-Author, “In-House Counsel’s Guide to Conducting Internal Investigations,” O’Melveny & Myers Handbook, (October 2010)
  • “New Incentives for Corporations to Maintain Effective Compliance and Ethics Programs,” O’Melveny & Myers Client Alert (May 2010)
  • “Start Talking — Or Else,” Legal Times (August 2008) (with Meaghan McLaine)
  • “Stolt-Nielsen Finally Gets Amnesty” (January 2008)
  • “Criminal Enforcement of Export Control/Sanctions Laws Announced as Top Priority of Justice Department and Partner Agencies Just as Higher Penalties Authorized” (October 2007)
  • “Negotiating Justice: Prosecutorial Perspectives on Federal Plea Bargaining in the District of Columbia,” 43 American Criminal Law Review 1063 (2006) (with Mary Patrice Brown)

District of Columbia Circuit Representative

  • United States Sentencing Commission's Practitioners Advisory Group (2011 to 2013)


  • Member, Council on Foreign Relations
  • Member, Trilateral Commission
  • Member, U.S. District Court for the District of Columbia Merit Selection Panel for U.S. Magistrate Judge Candidates (2020)
  • Distinguished Fellow, Syracuse University Institute for National Security and Counterterrorism (2019)
  • Co-Chair, American Bar Association Homeland Security Law Institute (2017 to present)
  • American Bar Association Advisory Committee to the Standing Committee on Law and National Security (2017 to present)
  • Stanford Law School, Board of Visitors (2008 to present)
  • Executive Board, Assistant United States Attorney Association (2002 to 2013)
  • Edward Bennett Williams American Inn of Court (1990 to present; Treasurer, 1999 to 2013) 
  • Barristers (2004 to 2013)


Alerts and Publications

CCPA Case Tracker

七月 1, 2020

Survey of Global Artificial Intelligence Regulation: An Evolving and Varied Landscape

六月 17, 2020

Recent Cyber Attacks on Critical Infrastructure Highlight Emerging Cyber Risks in the Water Industry

六月 10, 2020

California Attorney General Issues Final Proposed CCPA Regulations

六月 4, 2020

President Trump Issues Executive Order on Securing the United States Bulk-Power System

五月 6, 2020

President Issues Proclamation Limiting Immigrant Travel to the United States

四月 28, 2020

President Trump Issues Executive Order Creating Telecommunications Assessment Committee

四月 10, 2020

Practical Considerations for Directors: COVID-19

三月 25, 2020

President Trump Invokes the Defense Production Act

三月 20, 2020

Navigating Coronavirus “Shelter-in-Place” Orders Issued by Local Public Health Authorities

三月 18, 2020

O’Melveny Coronavirus Task Force: Data Security and Privacy Considerations During the COVID-19 Response

三月 16, 2020

The European Commission Proposes Artificial Intelligence Regulations That Could Reach Businesses Worldwide

三月 13, 2020

Attorney General Xavier Becerra Releases Modified CCPA Regulations

二月 18, 2020

Indictment of Chinese Military Hackers for Equifax Breach Highlights Important Data Security Lessons

二月 11, 2020

O’Melveny Releases State-by-State Guide to US Data Breach Notification Laws

一月 29, 2020

EU Advocate General Opinion Is a Mixed Bag for Companies Engaging in US-EU Data Transfers

一月 27, 2020

Supreme Court Leaves the Door Open for Expansive Biometric Privacy Lawsuits

一月 23, 2020

What’s Next in Data Security and Privacy? 6 Trends to Watch in 2020

一月 21, 2020

Failure to Apply Recent Microsoft Patch May Create Legal Liabilities

一月 15, 2020

California Attorney General Notifies California Consumers of Their Rights Under the California Consumer Privacy Act

一月 8, 2020

O’Melveny Releases CCPA Toolkit, A Resource for California’s New Privacy Law

十二月 19, 2019

EDPB Finalizes Guidance on GDPR Applicability Outside EU

十二月 11, 2019

Commerce Seeks Comment on Telecom Supply Chain Review Process

十二月 3, 2019

New Suit Against Spyware-Maker Demonstrates One Company’s Offensive Strategy Against Cyber Attacks

十一月 5, 2019

The Government Is Wielding Sticks and Carrots to Address National Security Concerns in the Telecommunications Sector

十月 3, 2019

Token Alliance Releases 2019 Edition of Best Practices Guide For Digital Tokens – AML Guidelines: O’Melveny Lawyers Serve As Expert Contributors

九月 12, 2019

Token Alliance Releases 2019 Edition of Best Practices Guide For Digital Tokens: O’Melveny Lawyers Serve As Expert Contributors

八月 14, 2019

Webinar Recap: Technology Companies’ Guide to Data Privacy

七月 31, 2019

California Consumer Privacy Act Update: A Slow Road to Changing the Face of US Privacy Law

五月 28, 2019

O’Melveny’s Fintech Group: Quick Facts

一月 26, 2019

A Prescription for Protecting Patients

一月 14, 2019

Expanded CFPB Sandbox Promises Greater Protections for Fintech and Other Financial Services Companies

一月 4, 2019

A Tale of Two Token Sales: the SEC Offers a Path Forward for Certain Unregistered Token Sales

十一月 27, 2018

DOJ Revises Guidance on Responding to Cyber Incidents

十月 11, 2018

Regulators Take Action Against Crypto Businesses

九月 14, 2018

In the News

Sky News: Virus Pandemic Lockdown

四月 14, 2020

Reuters: Explainer – Trump Has Little Power to Restart U.S. Economy

三月 24, 2020

WUSA-TV (CBS-9): Jack Evans Submits Paperwork to Run for DC Council Seat he Just Resigned From

一月 27, 2020

WRC-TV, NBC 4: DC Council Hears Investigator Testimony on Jack Evans’ ‘Ethically Questionable’ Actions

十一月 20, 2019

The Washington Post: He Earned $400,000 from Private Clients. But DC Council Member Jack Evans Couldn’t Explain What He Did for the Money.

十一月 20, 2019

The Washington Post: DC Council Hears from Lawyers Who Found Repeated Ethics Violations by Jack Evans

十一月 19, 2019

The Washington Times: Investigative Lawyers Defend Report on DC Council Member Jack Evans

十一月 19, 2019

Bloomberg Law: National Security Experience a Growing Draw for Big Law

九月 25, 2019

The Wall Street Journal Pro AI: NEC Sees Room for Growth in Business Use of Facial Recognition

九月 18, 2019

MSNBC “The Oath with Chuck Rosenberg” (Podcast): Lisa Monaco: Dr. Doom

五月 15, 2019

E&E News: How Hacking Threats Spurred Secret US Blacklist

四月 18, 2019

PYMNTS: New IoT Security Bill Exposes Rising Data Protection, Safety Concerns

三月 25, 2019

The National Law Journal: Ex-Obama Official Lisa Monaco Joins O’Melveny as Data Security and Privacy Co-Chair

三月 21, 2019

Law360: Trimmed Internet of Things Bill Could Still Carry Weight

三月 19, 2019

Bloomberg Law: CFTC’s New Foreign Bribery Focus Hinges on Companies’ Mea Culpas

三月 11, 2019 What’s Next: Protocol: Cryptic Canadian Crypto Case

二月 13, 2019 ‘Smart’ Plank of Wood Among IoT Devices Showcased at CES 2019

一月 11, 2019

Corporate Counsel: Q&A with O’Melveny’s Steve Bunnell: Cyber Risks Associated With Internet of Things

一月 10, 2019

Legaltech News: GDPR Fines Uncertain After British Airways’ Data Breach

十一月 8, 2018

American Bar Association: The Reliability and Risks of Blockchain Part 2 with Steve Bunnell

十月 12, 2018

American Bar Association: The Reliability and Risks of Blockchain Part 1 With Steve Bunnell

十月 4, 2018

Press Releases