Diana R. Shaw

Diana joined Wiley following a distinguished career in government. As the former Acting Inspector General of the U.S. Department of State and a former senior official at the Department of Homeland Security, she brings a wealth of knowledge and expertise to clients facing challenging public policy and other matters that combine legal and political risks and opportunities. Diana’s experience spans the full scope of congressional and executive branch investigations — from targeted information requests triggering little public attention, to some of the most high-profile and contentious investigations and oversight hearings posing significant legal, political, and reputational risks.

During her time at the Department of State, she led the Office of Inspector General’s criminal and civil investigative programs, which conducted numerous domestic and cross-border investigations of allegations of bid-rigging, bribery, kickbacks, fraud, and False Claims Act violations involving large U.S. and multi-national corporations. She has extensive experience investigating and auditing government contracting matters to assess and address potential non-compliance with federal regulations. She has also investigated some of the most senior officials in government (both political appointees and civil service executives) for ethics violations and other serious misconduct.

Diana understands that, often, the best defense against a government enforcement action is a strong compliance program. She has cultivated a deep understanding of key statutory compliance risk areas, including compliance with the Foreign Corrupt Practices Act, U.K. Bribery Act, False Claims Act, Medicare compliance guidelines, and securities laws. She conducts risk assessments and compliance program assessments and can develop and/or recommend enhancements to compliance programs for clients across a wide range of industries.

Drawing on her experience conducting risk and compliance program assessments, Diana can advise clients in matters involving institutional culture and social responsibility. She has overseen investigations involving workplace misconduct, harassment, and discrimination. She has also developed and led diversity, equity, inclusion, and accessibility (DEIA) programs and initiatives, conducted workplace culture assessments, and advised on organizational health matters.

Representative Matters

Litigation and Investigations:

• Investigated numerous large companies for alleged fraud, bid-rigging, and other wrongdoing related to corporate use of federal aid and/or participation in government programs.

• Spearheaded the effort to provide whole-of-government oversight of the $113 billion U.S. government response to the situation in Ukraine.
• Testified at multiple congressional oversight hearings on issues and investigations relating to government programs.

• Managed public relations challenges associated with congressional inquiries/investigations; advised Presidentially appointed nominees through the Senate confirmation process.
• Designed and executed a time-sensitive investigation of a prominent university’s handling of allegations of sexual assault that were first reported, and later retracted, by a U.S. media outlet.
• Helped obtain a $110 million settlement for a corporate client in a suit against former investors.
• Helped negotiate settlement of a government enforcement action for one-fifth the proposed fine amount (related to allegations of price-fixing by a non-U.S. airline).

Compliance:

• Set up a compliance program (from the ground up) for a foreign company following its acquisition by a large U.S. financial services firm.
• Regularly assisted clients with enhancing compliance programs, including developing and strengthening standards of conduct, anti-bribery and corruption policies and procedures, and third-party due diligence policies and procedures.
• Created and customized trainings for clients on industry-specific regulations and related compliance risks.

Advising and Counseling:

• Advised on all forms of congressional engagement, including how to engage with committee staff, responding to written inquiries, preparing to testify in a congressional hearing or sit for a congressional interview, and conducting outreach/engagement with individual Senators and Representatives.
• Assessed compliance with cybersecurity laws, regulations, and implementing policies; conducted cybersecurity risk assessments, including identifying system vulnerabilities; implemented cybersecurity safeguards and improved overall system efficiencies; investigated and remediated cybersecurity breaches.
• Advised on privacy matters, including matters involving U.S. or European Union privacy laws; assessed compliance with applicable privacy and data protection policies, laws, and regulations; implemented systemic privacy safeguards and internal controls; investigated and remediated privacy breaches.
• Assessed compliance with immigration policy, laws, and regulations; advised on asylum law and civil rights and civil liberties issues; evaluated the extent to which current and/or proposed immigration policies advanced policy goals and objectives.

Professional Experience

• Acting Inspector General/Deputy Inspector General, Office of Inspector General, U.S. Department of State (2020-2024)
• Office of Inspector General, U.S. Department of Homeland Security (DHS)
  • Head of Special Reviews and Evaluations (2019-2020)
  • Acting General Counsel / Head of Legal Affairs (2018-2019)
  • Acting Head of Congressional Affairs (February-May 2017)
• White Collar Defense Associate & Counsel, Am Law 100 Corporate Law Firm (2007-2016)

Recognitions

• During her tenure as the Acting Inspector General for the State Department (2020-2024), Diana’s office was recognized more than 20 times by the Council of the Inspectors General on Integrity and Efficiency (CIGIE) for excellence in auditing, investigation, and inspecting.
• Received the 2019 CIGIE Excellence Award for overseeing the special review of family separation issues under the Trump Administration’s Zero Tolerance Policy.
• Received the 2017 Inspector General Award for preparing the DHS Inspector General to testify at six congressional hearings within a six-week period.