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Massimo Contesso focuses on white collar crimes as well as internal investigations and national and international criminal and commercial litigation. Besides focusing on matters relating to compliance and corporations’ administrative and criminal liability under Italian Legislative Decree 231/2001, Massimo conducts cross-border internal investigations for domestic and international clients, assists in transnational anti-money laundering matters and anti-bribery and anti-corruption assessments.

Massimo handles internal investigations for major companies across Europe and the United States, evaluating whistleblowers’ complaints, coordinating document collection from a multitude of data sources and managing the effective review of the data across a wide range of investigative tools and e-discovery platforms, conducting witness interviews, preparing detailed investigative reports and coordinating the reporting to government authorities.

Massimo also assists companies in structuring corporate compliance programs, identifying weaknesses in internal policies, assessing follow-up actions as well as remediation and mitigation measures in order to avoid further violations, prevent regulatory and criminal action or assists clients in the criminal and regulatory litigation.

Concentrations

  • Internal investigations
  • Anti-corruption enforcement and compliance
  • Cross-border internal investigations
  • Criminal and regulatory investigations
  • Public corruption
  • Money laundering
  • Anti-money laundering compliance
  • Anti-bribery and anti-corruption assessment
  • Compliance
  • Italian Legislative Decree 231/2001
  • Market abuse
  • Government investigations

Capabilities

Experience

Massimo has deep experience in setting up, conducting and coordinating cross-border white-collar investigations in financial crimes, market abuse, leaks of confidential information, insider trading, sexual harassment, money laundering, complex corporate fraud schemes, and corruption, and in identifying wrongdoings, illicit practices and internal policy violations across a wide spectrum of businesses, including health care, pharmaceutical, oil & gas, transportation, banking, tobacco and paper industries, as well as computer technology and the luxury sector.

  • FCPA investigations
    • Assisted in representing a leading international health care company in connection with a criminal investigation involving alleged improper payments made by an Italian distributor to the manager of the regional health authorities and providing assistance in the related internal investigation into possible violations of the FCPA in Italy, conducted in coordination with the U.S. counsel and with the US Department of Justice and the Securities and Exchange Commission.°
  • Health Care/Pharma matters
    • Assisted a leading global biotechnology company focused on serving people with rare diseases in conducting the Italian law portion of a global anti-bribery and anti-corruption due diligence and risk assessment in order to integrate two legacy organizations following a merger.°
    • Advised the Italian subsidiary of a leading global biotechnology company focused on serving people with rare diseases on the update and integration of its organizational model, its code of ethics and its internal procedures adopted pursuant to Legislative Decree No. 231/2001.°
    • Assisted a leading global biotechnology company in connection with an internal investigation concerning alleged corruption in the health care sector potentially involving the company’s top level management as well as doctors and third parties and companies. Also assisted the client in reviewing the business processes across the organization, identifying and determining where any corruption risks existed, ensuring compliance with relevant local and international anti-corruption laws, developing tailored mitigation strategies, and ensuring an integrated and workable anti-corruption compliance program.°
  • Anti-Money Laundering
    • Assisting a Dutch investment fund and its shareholder and directors – in connection with its purchase of a leading betting and gaming company – on the criminal proceedings - and a concurrent internal investigation - regarding accusations of criminal association and money laundering.°
    • Assisting the Italian subsidiary of a multinational conglomerate leader in the luxury sector in connection to possible anti-money laundering violations and in reporting to the relevant authorities.°
  • Market abuse, insider trading, leak of confidential information
    • Assisted the Chief Executive Officer and major shareholder of a leading international service provider to the oil and gas industry listed on a foreign stock exchange in a number of disputes, also involving cross-border aspects, against Consob, the Italian National Commission for the Stock Exchange, to appeal a resolution which sanctioned the client for insider trading violations.°
    • Assisted one of the leading European financial institutions in the internal investigations carried out as a result of an alleged leak pertaining to the bank’s upcoming strategic review and capital increase. This assignment, inter alia, involved several issues concerning market abuse regulations and related liaising with Consob, the Italian National Commission for the Stock Exchange.°
    • Assisted one of the leading European financial institutions in the internal investigations carried out as a result of an alleged leak pertaining to a potential transaction.°
  • Compliance programs and Organizational Models pursuant to Italian Legislative Decree 231/2001
    • Assisted a leading railway company on the review of their organizational model pursuant to Legislative Decree No. 231/2001.°
    • Assisted various companies operating in the oil & gas sector in the review of their anti-bribery policies, in the implementation of their compliance programs, in conducting risk assessments and interviews conducted in compliance with Legislative Decree No. 231/2001, and in reviewing their global anti-corruption program.°
    • Assisted a company (belonging to 3 consortia of large energy-intensive industrial clients in the steel, paper and chemical sectors in Italy) on the implementation and update of its organizational model pursuant to Legislative Decree No. 231/2001.°
  • Private corruption
    • Advised the Italian subsidiary of a European leader in the mailing and express courier services in connection with the assessment - in light of Italian and other European anti-bribery regulations - of the risks and precautions to be adopted in planning social events with customers and business partners.°
  • Internal investigations on anti-corruption matters
    • Assisted a U.S. multinational computer technology corporation on internal investigations on the possible violation of corporate policies as part of the execution of an agreement for the sale of user licenses with a public sector counterparty.°
    • Assisted a U.S. multinational computer technology corporation on internal investigations for alleged violations of anti-corruption laws and of their compliance programs.°
  • White Collar criminal defense
    • Assisting the Italian subsidiary of a French multinational company operating worldwide in rail transport markets in a criminal proceeding pending before the Tribunal of Milan regarding alleged public corruption as well as in the connected internal investigations and potential review of the compliance system.°
    • Assisting the Italian subsidiary of a French multinational company operating worldwide in rail transport markets in the assessment of the impact of the criminal proceedings on existing public contracts, participation to public tenders and managing issues arising within the contractual relationships with business partners, as well as assistance in replying to the requests of clarifications of business partners.°

°The above representations were handled by Mr. Contesso prior to his joining Greenberg Traurig Santa Maria, an affiliate of Greenberg Traurig, P.A. and Greenberg Traurig, LLP.

  • Senior associate, Milan office of an international law firm headquartered in New York, New York, United States, 2019-2023
  • Associate/trainee lawyer, Milan office of an international law firm headquartered in Los Angeles, California, United States, 2016-2019
  • Intern, Milan office of an international law firm headquartered in Los Angeles, California, United States, 2014

Recognition & Leadership

  • Listed, The Legal 500 EMEA, Rising Stars, Compliance, 2024
  • Member, Milan Bar Association

Credentials

Education
  • Master in Strategy and Entrepreneurship, SDA Bocconi School of Management, 2021
  • Master in Corporate Criminal Law, Just Legal Services, 2018
  • J.D., Bocconi University, 2016
  • Pennsylvania State University, The Dickinson School of Law, Exchange Program, 2013
Admissions
  • Italy
Languages
  • Italian, Native
  • English, Fluent