Kara L. Kapp


Kara helps companies implement proactive compliance programs to mitigate risks of downstream exposure and reinforce a positive corporate culture. Her practice has a special focus on representing executives and entities in the cryptocurrency, financial, and sports wagering industries, in representing foreign defendants, and in representing defendants in federal sentencing proceedings. She has published numerous thought pieces on these subjects. She also represents Fortune 500 entities, corporate executives, and foreign defendants at every stage of regulatory investigations and federal criminal enforcement actions in white collar matters. She has helped clients navigate allegations of securities fraud, health care fraud, false statement claims, tax fraud, antitrust offenses, environmental offenses, Foreign Agent Registration Act violations, and Foreign Corrupt Practice Act violations, among others. 

Kara has significant experience briefing trial and appellate matters before the U.S. Courts of Appeals, the U.S. Supreme Court, federal district courts, and the Illinois Appellate Court. She is a member of the U.S. Supreme Court, Illinois, California, and D.C. bars, and she is admitted to practice in the Seventh Circuit and the Northern District of Illinois, and the District of Columbia.

She earned her undergraduate degree, summa cum laude, from Dartmouth College in 2006, double majoring in international relations and environmental studies. In 2010, she earned her J.D. from Stanford Law School, as well as a masters in Latin American studies. She is fully proficient in Spanish and proficient in reading and writing in Portuguese. While at Stanford, she served as a symposium editor of the Stanford Law Review, where she received multiple awards for her service. She also worked as a constitutional and international law research assistant to Stanford Law School Dean Jenny Martinez. After law school, Kara served as a law clerk to then Chief Judge Bruce D. Black of the U.S. District Court for the District of New Mexico and to the Honorable Edward L. Chavez of the New Mexico Supreme Court. 


Criminal Defense and Sentencing

Defended two clients, investment advisory firm and its chief compliance officer, in a civil contempt proceeding in California, where such proceedings are quasi-criminal. After 7 days of proceedings involving witness examinations and multiple motions raising constitutional objections, the court granted motions for acquittal as to both clients.

Defended the founder of a well-known internet gambling site against federal felony charges with exposure of up to 20 years imprisonment. Ultimately, prosecutors dropped the felony charges in exchange for a guilty plea on a misdemeanor charge, resulting in a sentence of unsupervised probation and payment of a fine. The client also was able to reacquire a domain name that had been forfeited during the course of the prosecution. 

Negotiated a settlement agreement with the potential to revolutionize the U.S. sports-betting market on behalf of Laura Varela and 5Dimes, a popular offshore sportsbook in Costa Rica. The U.S. Department of Justice had been investigating illegal gambling and money-laundering activity associated with 5Dimes and Ms. Varela’s husband at the time of his death in 2018. Our team negotiated an unprecedented resolution with prosecutors in the Philadelphia U.S. Attorney’s Office that resolved 5Dimes’s legal liability and that allowed Ms. Varela to reposition the sportsbook to enter the regulated U.S. sports-betting industry. Further, the Government expressly agreed to advise state regulators, banks, and investors about her extraordinary cooperation and impressive efforts to transform 5Dimes into a lawful, regulated company. 

Represented an individual under criminal investigation by the Special Counsel’s Office. After extensive meetings with Special Counsel, it decided not to pursue charges against our client.

Served as lead counsel at the sentencing phase to a defendant charged with bribery and wire fraud in connection with services provided to the D.C. government. The sentencing advocacy persuaded the Probation Office to withdraw a proposed aggravating role enhancement and make a rare formal recommendation to the court to grant the defendant a downward variance. The sentencing advocacy further convinced the court to grant a 3-level downward variance to a sentence of 41 months, where the court found that the applicable guideline range was 57-71 months.

Represented an executive of a biofuel company at sentencing and in cooperation efforts in connection with a federal tax fraud prosecution and sentencing. Based on advocacy at sentencing, the judge issued the client a below-guideline sentence of 87 months, substantially shorter than his co-defendants received. Subsequently secured client’s release during the pandemic due to fragile health and vulnerability to COVID-19. The client was among the first seven inmates at his institution to be granted release in the wake of the pandemic. The client ultimately served only a year and a half of his original 87-month sentence.

Represented CEO of publicly traded health care company at trial and sentencing in $85 million health care fraud scheme. Our advocacy at sentencing convinced the judge to sentence the client to 36 months in prison, where the court found the applicable sentencing guidelines range was 121-151 months imprisonment.


Represented several organizations and professors in drafting cert- and merit-stage amicus briefs on matters of public importance.

Represented a high-level foreign public official in a prosecution and mandamus appeal in the Seventh Circuit challenging the validity of an indictment.

Served on a team that successfully represented a woman wrongfully convicted of murder before the Seventh Circuit on habeas review and before the Supreme Court, successfully convincing the Court not to grant the writ or issue a summary reversal.

Represented an individual before the Seventh Circuit on the merits and at oral argument in an appeal of a criminal conviction.

Compliance & Internal Investigations Experience

Completed a six-month secondment with Anheuser Busch InBev’s Global Compliance Team. During this secondment, conducted internal investigations, led witness interviews in Spanish & English, led project to draft and update the company’s compliance policies, and gained familiarity with AB InBev’s award-winning compliance data analytics platform, BrewRIGHT.

Participated in many internal investigations, including over 100 witness interviews, and have led over 40 witness interviews.

Provided comprehensive analysis of U.S. trade sanctions for an international energy company, and advised on a recommended compliance protocol.

Advised gaming companies on compliance issues and business opportunities for sports relating to the Supreme Court’s landmark decision in Murphy v. NCAA (2018).

Represented a gaming entity before a regulatory body to advocate for regulations to permit entity betting.

Advised major cryptocurrency issuers, investors, wallet providers, and mining companies on regulatory and compliance issues.




13 Cozen O'Connor Attorneys Named 2022 D.C. Super Lawyers and Rising Stars

July 12, 2022

Super Lawyers has named 13 Cozen O’Connor attorneys to its 2022 Washington D.C. Super Lawyers and Rising Stars lists.

Kara Kapp Named National Law Journal’s 2021 DC Rising Star

November 17, 2021

The Rising Stars award recognizes and celebrates professional excellence of 40 young lawyers who represent a cross-section of practice areas and have “proven their mettle where it counts, representing high-profile clients and securing high-dollar victories.”

Twelve Cozen O’Connor Attorneys Recognized as Washington, D.C., Super Lawyers and Rising Stars

May 05, 2021

Super Lawyers has named 12 Cozen O'Connor attorneys to its 2021 Washington, D.C., Super Lawyers and Rising Stars list.

Cozen O’Connor Negotiates Historic Settlement for Offshore Sports-Betting Company

October 01, 2020

Barry Boss, Stephen Miller, and Kara Kapp negotiate a historic non-prosecution agreement involving 5Dimes, a major offshore sports-betting operator.

Fourteen Cozen O’Connor Attorneys Recognized as Washington, D.C., Super Lawyers and Rising Stars

April 20, 2020

Super Lawyers has named 14 Cozen O'Connor attorneys to its 2020 Washington, D.C., Super Lawyers and Rising Stars list.

13 Cozen O'Connor Attorneys Recognized as Washington, D.C. Super Lawyers and Rising Stars

April 25, 2019

The 2019 Washington, D.C, edition of Super Lawyers Magazine, published by Thomson Reuters, has named 13 Cozen O’Connor attorneys to its list of Super Lawyers and Rising Stars.


The Ripple effect—when a ripple becomes a wave

August 14, 2023

Kara L. Kapp wrote the article, “The Ripple effect—when a ripple becomes a wave” published by Westlaw Today. The article discusses two major recent decisions applying U.S. securities registration requirements to digital assets.

DOJ Enforcement Against Cryptocurrency Exchanges

May 10, 2022

Kara Kapp discusses a guilty plea by two co-founders of a cryptocurrency exchange in an article published by the Banking Law Journal.

The ‘Ripple’ Effect: A Striking Development on Defending Digital Asset Securities Litigation

April 21, 2022

In an article published by Thomson Reuters Westlaw, Kara Kapp discusses the implications of the court’s acceptance of Ripple Labs’ fair notice defense in the SEC litigation against the company and two of its executives, which has potentially wide-ranging implications for digital asset markets.

The Importance of a Racially Diverse Sentencing Commission [Fed. Sentencing Reporter]

April 01, 2022

Barry Boss and Kara Kapp published an article in Federal Sentencing Reporter (Vol. 34, Issue 4, Apr. 2022), titled “The Importance of a Racially Diverse Sentencing Commission.”

The White House Calls for a Sweeping Review of the Government’s Approach to Cryptocurrency [Alert]

March 15, 2022

Kara Kapp discusses President Biden's Executive Order on Ensuring Responsible Development of Digital Assets.

A Blockbuster Week for DOJ Enforcement against Cryptocurrency Exchanges [Alert]

March 02, 2022

Kara Kapp discusses two co-founders of a cryptocurrency exchange, BitMEX, Arthur Hayes and Benjamin Delo, pleading guilty to violating the Bank Secrecy Act by failing to implement and maintain an anti-money laundering program. The court overseeing the BitMEX prosecution also denied a motion to dismiss the indictment against the third co-founder of BitMEX.

Rerouting the Wire Act: Can Statutory Interpretation Save the Wire Act from the Threat of Intermediate Routing Prosecutions? [Gaming International Online]

October 01, 2021

Barry Boss and Kara Kapp published an article in Gaming International Online, which tackles a thorny legal question that has persisted since the advent of the Internet - whether and how the Interstate Wire Act of 1961 applies to Internet communications, and whether this 50-year-old law can be squared with America’s increasing legalization of Internet-based sports wagering activities.

How the Economic Loss Guideline Lost its Way, and How to Save It [Ohio State Journal of Criminal Law]

August 23, 2021

Cozen O’Connor attorneys Barry Boss and Kara Kapp published an essay in the Ohio State Journal of Criminal Law on the arbitrary and disproportionate sentencing recommendations driven by the economic crimes sentencing guideline.

Gensler's SEC Can Bring Regulatory Clarity to Digital Assets

April 14, 2021

Chris Bellini and Kara Kapp discuss potential changes to be made to the digital assets industry as a result of Gensler’s recent appointment as chairman of the Securities and Exchange Commission in ThinkAdvisor.

The Department of Justice Announces the First-of-its-Kind Cryptocurrency Enforcement Framework [Alert]

October 09, 2020

Barry Boss and Kara Kapp discuss the DOJ Cyber-Digital Task Force 83-page framework intended to help cryptocurrency entrepreneurs understand and comply with U.S. legal obligations.

Has the SAFT Been KIKed to the Curb?

October 02, 2020

Kara Kapp discusses the court's decision in Securities and Exchange Commission v. Kik Interactive, Inc.

Cozen O’Connor Negotiates Historic Settlement for Offshore Sports-Betting Company [Alert]

September 30, 2020

Barry Boss, Stephen A. Miller, and Kara Kapp discuss the non-prosecution agreement involving 5Dimes.

Importance of a Robust Compliance Program Underscored by DOJ’s Updated Corporate Compliance Guidance [Alert]

June 04, 2020

Martin Bloor and Kara Kapp discuss the new DOJ guidance and the importance to make regular efforts to update their programs and to reinforce company policies in the wake of breaches to strengthen their effectiveness.

Court Reverses Foreign National’s FCPA Conviction, Setting a High Bar to Establish an Agency Relationship [Alert]

February 28, 2020

A ruling issued on Wednesday, February 26 by a Connecticut federal court details the type of control necessary to find that a foreign national acted as an agent of a U.S. domestic concern for purposes of falling within the coverage of the Foreign Corrupt Practices Act (FCPA).

Emerging Trends Under the DOJ’s Corporate Enforcement Policy

February 20, 2020

Niki Sprinzen and Kara Kapp (White Collar Defense & Investigations) authored an article in Corporate Compliance Insights, titled Emerging Trends Under the DOJ’s Corporate Enforcement Policy, offering guidance to help compliance professionals navigate the FCPA landscape given what lies ahead, particularly in terms of white-collar prosecutions.


  • Stanford University Law School, J.D., 2010
  • Stanford University, M.A., 2010
  • Dartmouth College, B.A., summa cum laude, 2006

Awards & Honors

Rising Star, National Law Journal Legal Awards 2021

DC Super Lawyers’ Rising Stars (White Collar Defense & Investigations): 2018 - 2022

2017 Cozen O’Connor D.C. Pro Bono Lawyer of the Year Award

2014 Seventh Circuit Bar Association Pro Bono and Public Service Award

Stanford Law School, Pro Bono Distinction

Stanford Law Review Vol. 62 Special Service Award

Stanford Law Review Vol. 62 Symposium Committee Award for Exceptional Commitment

American Constitution Society, Stanford Law School Chapter, Programming Award 2010

Dartmouth College, Rufus Choate Scholar

Dartmouth College, Downey Family Prize in Environmental Studies (honoring top Environmental Studies student)

Environmental Studies Honors Thesis: The International Politics of Rainforest Management

  • California
  • Illinois
  • District of Columbia
  • U.S. Supreme Court
  • U.S. Court of Appeals for the Fourth Circuit
  • U.S. Court of Appeals for the Seventh Circuit
  • U.S. Court of Appeals for the Ninth Circuit
  • U.S. Court of Appeals for the D.C. Circuit
  • U.S. District Court – District of Columbia
  • U.S. District Court – Northern District of California
  • U.S. District Court -- Northern District of Illinois

Chief Judge Bruce D. Black, U.S. District Court -- New Mexico

Honorable Edward L. Chavez, New Mexico Supreme Court

American Bar Association, Women in White Collar Subcommittee, Criminal Justice Section

ACLU of Northern Illinois, Next Generation Society Member

American Constitution Society, D.C. Chapter, Board Member

Illinois State Bar Association

Justice Council of Northwestern Law School, Board Member

National Association of Criminal Defense Lawyers