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Kimberly Brunelle Willis

Of Counsel

555 17th Street, Suite 3200, Denver, CO 80202

Kim provides sophisticated counsel to local and multinational entities and individuals in complex civil litigation and enforcement proceedings and advises clients in internal investigations and corporate compliance matters.

Kim represents clients facing high-stakes complex civil litigation in federal and state trial and appellate courts; enforcement proceedings, including with the DOJ, SEC, CFTC and state agencies; and inquiries by self-regulatory agencies, including FINRA and the NFA.

She guides companies through all stages of litigation and investigation and advises on compliance issues and corporate best practices. From her secondment at Citigroup, Inc., where she managed regulatory and internal investigations, enforcement and litigation proceedings, Kim understands these matters from a client’s perspective. Her background includes securities, derivatives, banking, mergers and acquisitions, insider trading, investment advisors, bribery and corruption (FCPA and UK Bribery Act), shareholder derivative actions, class actions, commercial disputes and corporate governance. 

Prior to joining Holland & Hart, Kim practiced for six years as a litigation and enforcement attorney at Cleary Gottlieb Steen & Hamilton LLP in New York. Kim also served as a law clerk to the Honorable William G. Young of the United States District Court for the District of Massachusetts.

Client Results

  • Before joining Holland & Hart, Kim worked on the following matters:

    Client Secondments  
    • Associate General Counsel at Citigroup, Inc. in the Institutional Clients Group Litigation and Regulatory Enforcement team for seven months. Managed a broad range of regulatory and internal investigations, enforcement and other inquiries conducted by federal and state regulatory authorities and self-regulatory agencies. Interfaced with enforcement attorneys and examination staff at the DOJ, SEC, FINRA and state regulatory authorities, prepared responses to subpoenas and civil investigative demands (CIDs) and advised businesses on strategy and resolutions. Oversaw a variety of domestic and international civil litigation, including securities class actions, commercial disputes, and merger and acquisition matters. Responded to civil subpoenas, managed litigation discovery and prepared witnesses for testimony.
    Enforcement, Investigations and Compliance  
    • Represented European bank in a Dodd-Frank swap dealer compliance investigation conducted by the CFTC. Delivered multiple presentations to the CFTC and NFA. The matter was resolved in a favorable settlement order.
    • Advised Mexican infrastructure company in a domestic regulatory banking investigation, and an assessment of potential exposure to U.S. securities laws and Foreign Corrupt Practices Act (FCPA). The investigation resolved in a favorable settlement order with no collateral impact in the U.S.
    • Represented major international bank in trading investigation by the SEC. Successfully defended matter on jurisdictional grounds.
    • Advised large Middle Eastern sovereign wealth fund on anti-corruption issues under the FCPA and UK Bribery Act in connection with a high-risk asset acquisition.
    • Counseled major international bank on Sarbanes-Oxley Act (SOX) compliance requirements.
    • Counseled multinational clients on FCPA compliance issues and advised on anti-corruption policies and procedures.
    Complex Civil Litigation  
    • Defended financial guaranty insurer in New York State Court in a $1.4 billion litigation and appeal involving contractual and valuation claims for terminated credit default swaps. Won partial motions for dismissal and summary judgment.
    • Defended European bank in Madoff feeder fund litigation in U.S. Bankruptcy Court (SDNY) and British Virgin Islands.
    • Defended major international law firm in a series of employment law actions. Negotiated dismissal of one action and settlement of two other actions.
    • Handled third-party subpoenas for multinational companies and international banks.
    • Conducted and defended depositions in private tort actions brought against New York City as Assistant Corporation Counsel on secondment at the New York City Law Department.
    Pro Bono Representation  

    Handled high-profile pro bono matters, including:

    • Obtained asylum for three Pakistani women after serving as lead counsel for the women in U.S. Attorney's Office (EDNY) prosecution involving honor killings.

    • Vacated New York criminal convictions and obtained visas for sex trafficking victims.

    • Drafted organizational documents and obtained tax exemption for the second-ever New York charitable bail fund.



Speaking Engagements


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Court Admissions


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