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Bradley Arant Boult Cummings LLP

Gene R. Besen

Gene R. Besen



  • Government Enforcement and Investigations

WSG Practice Industries



Gene Besen advises corporations and individuals across the country in navigating investigations, civil enforcement actions and criminal proceedings brought by various government agencies. He represents clients in a wide range of industries – including healthcare, telemedicine, pharmaceuticals, financial services, and others – that need proactive strategies to mitigate and avoid controversies related to allegations involving billing fraud, kickbacks, securities fraud, insider trading, FCPA violations, pay-to-play schemes, antitrust violations and price fixing.

Gene has guided clients to favorable outcomes in investigations and criminal prosecutions brought by the enforcement agencies that oversee their activities, including the Department of Justice (DOJ), Department of Health and Human Services, Securities and Exchange Commission (SEC), Financial Industry Regulatory Authority (FINRA) and Texas State Securities Board. Focused on preventing government intervention altogether, he regularly helps clients develop compliance policies and conduct internal investigations and audits to identify emerging issues before they become problems.

Gene also has extensive experience representing telemedicine companies, hospitals, physicians, pharmacies, laboratories, pharmaceutical corporations, financial institutions, hedge funds and utilities in a wide range of civil and commercial litigation matters. These disputes typically involve claims related to white-collar criminal matters, including False Claims Act violations, healthcare fraud, securities fraud, kickbacks and clawback actions involving alleged fraudulent transfers.

His experience handling investigations and enforcement proceedings allows him to help clients expand and protect their businesses. Gene serves as outside general counsel for several entrepreneurs and growing companies across the country, advising on the day-to-day challenges and opportunities that arise during the lifecycle of their businesses.

Bar Admissions

  • Texas, 2004

Court Admissions
  • United States Court of Appeals, 5th Circuit
  • United States District Court, Eastern District of Texas
  • United States District Court, Northern District of Texas
  • United States District Court, Southern District of Texas
  • United States District Court, Western District of Texas
  • United States District Court, Western District of Michigan


  • Southern Methodist University Dedman School of Law, J.D., 2004
  • Brandeis University, B.A., 2001
Areas of Practice

Government Enforcement and Investigations


OIG Takes Aim at Speaker Programs in Special Fraud Alert
Bradley Arant Boult Cummings LLP, November 2020

On November 16, 2020, the Office of Inspector General of the Department of Health and Human Services (OIG) issued a Special Fraud Alert addressing the fraud and abuse risks of speaker programs that are commonplace in the pharmaceutical and medical device industries...

WSG's members are independent firms and are not affiliated in the joint practice of professional services. Each member exercises its own individual judgments on all client matters.

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