Salary · White collar 2026
White collar attorney salary 2026: law firm versus in-house.
The 2026 figure is still priced off a dated Department of Justice docket, not off a dead statute. One table, year inside every cell, for the lawyer who earns it and the general counsel who pays it.
The docket still writes the paycheck.
New York is the research city behind this US pay table. Across 1,675 structured interviews with New York partners and counsel, 71 of 124 investigations associates, counsel and in-house investigations lawyers over a 24-month window said their 2026 cash conversation opened on the enforcement calendar, not on the lockstep memo.
A general counsel pricing a 2026 white collar lawyer salary against an associate offer is not comparing one number to another; she is comparing two products. The firm-side product is a lockstep that moved on 2 June 2026. The in-house product is an Association of Corporate Counsel title median that still carries a 1 March 2025 effective date. Both are paid, in 2026, against a Department of Justice calendar that paused new Foreign Corrupt Practices Act matters, restarted them under four US-interest factors, and then rebuilt the rest of the white-collar docket around healthcare, trade fraud and a Department-wide Corporate Enforcement Policy.
Executive Order 14209, signed 10 February 2025, directed the Attorney General to cease new FCPA investigations and enforcement actions for 180 days, review existing matters, and issue updated guidelines. Existing indictments were reviewed case by case. A freeze on new matters, not a repeal.
Four dates, two seats, three payers. The table in the next section is the cash. Year sits inside every cell.
- $123M
- DOJ corporate FCPA collections, 2025, across three actionsAgainst $1.28 billion across eleven core actions in 2024
- Gibson Dunn 2025 Year-End FCPA Update, 8 January 2026
- $16B
- Fraud Section intended fraud loss charged in 2025A record; more than double the prior year
- Jenner & Block on the DOJ Fraud Section Year-in-Review, 29 January 2026
- $1B+
- Trade Fraud Task Force recoveries, penalties, forfeiture and charged losses by 14 July 2026Launched August 2025 as a DOJ–DHS effort
- King & Spalding, 9 September 2026
- +4.2%
- Big Law demand, first half of 2026 versus historical 1.5–2%The cycle that funded the June lockstep raise
- Citi via Law.com, 17 August 2026
The 2026 white collar lawyer salary table, firm versus in-house.
There is no blended white-collar product. There is a lockstep, a set of in-house title medians, a General Schedule band, and a national lawyer wage that is the floor, not the work.
The cells below are the published instruments, not a Sartori blend. Bloomberg Law reported on 2 June 2026 that Milbank raised associate bases by $10,000 for years one through four and $20,000 for years five through eight, producing a $235,000 first-year through $455,000 eighth-year ladder effective 1 July 2026. Biglaw Investor’s 2026 tracker puts all-in cash, with the 2025 Cravath year-end bonus and specials rolled forward, at $256,000 for a first-year and $585,000 for an eighth-year. The Association of Corporate Counsel / Empsight 2025 Law Department Compensation Survey, data effective 1 March 2025 across 1,632 US respondents, puts in-house attorney median base at $148,000 and general counsel / chief legal officer median base at $330,000, with median total cash of $160,000 and $410,000 respectively.
The Bureau of Labor Statistics Occupational Outlook Handbook, last modified 27 August 2026, puts the May 2025 median annual wage for all lawyers at $159,670. That is the national denominator. It is not a white-collar investigations figure. A Trial Attorney posting for the FCPA and Market, Government and Consumer Fraud Units, open on USAJOBS from 23 June to 17 July 2026, listed GS-14/15 at $143,913 to $197,200 under the 2026-DCB locality table. The public credential is cheaper than the first-year lockstep that buys the alumni.
| Seat | Base | All-in / total cash | Year | Instrument |
|---|---|---|---|---|
| Elite firm, 1st-year associate | $235,000 | $256,000 | 2026 (eff. 1 Jul) | Milbank / Biglaw Investor |
| Elite firm, 8th-year / senior associate | $455,000 | $585,000 | 2026 (eff. 1 Jul) | Milbank / Biglaw Investor |
| NALP first-year median, all firm sizes | $200,000 | n/a | as of 1 Jan 2025 | NALP, 28 May 2025 |
| NALP first-year, firms of 701+ | $215,000 | n/a | as of 1 Jan 2025 | NALP, 28 May 2025 |
| In-house Attorney (ACC median) | $148,000 | $160,000 cash | eff. 1 Mar 2025 | ACC 2025 survey |
| In-house Associate General Counsel | $245,000 | $294,000 cash | eff. 1 Mar 2025 | ACC 2025 survey |
| In-house GC / Chief Legal Officer | $330,000 | $410,000 cash | eff. 1 Mar 2025 | ACC 2025 survey |
| DOJ FCPA / MGC Trial Attorney (DC) | $143,913–$197,200 | n/a | 2026 DCB locality | USAJOBS; OPM |
| BLS all-lawyers median (SOC 23-1011) | $159,670 | n/a | May 2025 OEWS | BLS OOH, 27 Aug 2026 |
| Am Law 100 average PEP | n/a | $3.59 million | 2025 performance | Am Law 100, 14 Apr 2026 |
The Am Law 100 average profits per equity partner of $3.59 million, published 14 April 2026 on 2025 performance, is a firm-wide average, not a white-collar partner W-2. No published 2026 white-collar-only associate or partner W-2 sits behind this table; omit any blended “FCPA lawyer salary.”
Attorney median total target
17 percent LTI-eligible. Target, not realized equity.
ACC 2025 Law Department Compensation Survey, pp. 9–10 ↗One derived read from those two instruments: an eighth-year associate’s $585,000 all-in cash on the 2026 Milbank tracker can exceed the $503,000 median total target of a US general counsel / chief legal officer on ACC’s March 2025 survey, before the GC’s 90th-percentile tail. The lawyer who earns the lockstep and the chief legal officer who pays the invoice are not on the same ladder. They are on two ladders that crossed in 2026.
The lockstep is the same product for a white-collar associate as for a corporate associate at a matching firm.
- Year-end cash still compresses. Cravath’s 18 November 2025 memorandum set year-end bonuses from $20,000 (class of 2024) to $115,000 (class of 2018 and senior), plus specials of $6,000 to $25,000, a combined senior top of $140,000. Global Legal Post recorded on 25 November 2025 that Paul Weiss, McDermott Will & Schulte, Dechert, Vinson & Elkins, Debevoise, Baker Botts, Cadwalader, White & Case, Skadden, Davis Polk, Fried Frank and Milbank matched. The June 2026 base raise did not reset that grid.
- No sourced white-collar premium exists. Nothing in the 2026 tracker or the NALP survey isolates an investigations uplift on the lockstep. Do not budget one. The credential that clears the 2026 cash is a government-enforcement tour, not a second exam.
- The public seat is the feeder. USAJOBS required a J.D., an active US bar, 2.5 years post-J.D. for GS-14 and four years for GS-15, with preferred experience as a criminal prosecutor on complex white-collar and corporate investigations. Firm practice pages treat former AUSA, Department of Justice, Securities and Exchange Commission and Commodity Futures Trading Commission time as the hiring signal.
The general counsel writes two checks: the internal salary, and the Am Law invoice the internal hire does not replace.
- Most in-house counsel came from firms. ACC’s 2025 survey found 77 percent of in-house respondents had law-firm experience before moving in-house, and 16 percent went law-school-to-in-house. Prior firm experience carried a 16 percent Attorney median-base premium and a 21 percent chief legal officer median-base premium, per ACC Corporate Counsel Now on 16 September 2025.
- Specialty pay is visible at the individual-contributor rung. ACC ranks securities, antitrust and bankruptcy/creditor as the highest-compensated in-house specialties, above IT, corporate contracts and entertainment. The survey does not publish a separate investigations or FCPA band. Securities and antitrust is the nearest published proxy for enforcement-adjacent in-house work.
- Disclosure routing is now a staffing brief. The 10 March 2026 Corporate Enforcement Policy applies across the Department except Antitrust. National Security Division guidance, as reported by Mondaq on 22 July 2026, confirms that a disclosure only to the Bureau of Industry and Security, the Office of Foreign Assets Control or the Directorate of Defense Trade Controls does not earn CEP credit. The criminal disclosure has to go to the National Security Division. A company with procurement exposure and a foreign-bribery angle may face two components on one fact pattern.
They are on two ladders that crossed in 2026.
The lockstep did not wait for FCPA collections to recover.
Litigation and investigations platforms matched first. A five-month-old Washington boutique matched the full scale in September. The associate who earns that cell is paid from firm-wide demand.
NALP’s 2025 U.S. Associate Salary Survey, covering 437 responding offices as of 1 January 2025 and released 28 May 2025, put the overall first-year median base at $200,000 and $215,000 at firms of 701 or more lawyers, both flat versus 2023. Eighty-seven percent of responding offices sat at firms of more than 250 lawyers. $225,000 was the modal figure, reported by 32 percent of all offices and 45 percent of offices at 701-plus. Six cities already sat at a $225,000 first-year median: Austin, Boston, Houston, New York City, San Francisco and the Washington DC area. That is the pre-raise map of where white-collar firm seats cluster. By class year, all-size medians ran $200,000, $210,000, $220,625, $238,125, $255,000, $271,175, $286,700 and $330,000 from first year through eighth; at firms of 701-plus the eighth-year median was $375,000. The June 2026 Milbank move put a $10,000 to $20,000 step on top of a ladder that had been flat since late 2023. A New York investigations associate who reads only the NALP median is a year behind the lockstep that boutiques are already matching.
David Lat, writing in Bloomberg Law on 17 June 2026, recorded more than a dozen matches within two weeks of Milbank, with litigation boutiques among the first movers; only five of the early movers sat in the Am Law 100. On 8 September 2026 a Washington white-collar and investigations boutique founded in April 2026 matched the full $235,000 to $455,000 scale effective immediately. The buyer paying 2026 associate cash for investigations work is often a boutique or a litigation specialist, not only a full-service New York lockstep firm.
The capital behind that cash is firm-wide. The 2026 Am Law 100, published 14 April 2026, put 2025 collective revenue growth at about 13 percent, net income up 16.3 percent and profits per equity partner up 14.0 percent, on aggregate gross revenue of $178.95 billion. Wells Fargo Legal Specialty Group, cited by Global Legal Post on 25 November 2025, put top-50 grossing firms up 12.4 percent in revenue across the first three quarters of 2025, with a 10 percent billing-rate increase as the primary contributor. None of those series is a white-collar practice P&L. They are why the lockstep could move while 2025 corporate FCPA collections collapsed.
Partner cash is a different product again. Public ALM-derived tables circulating with the 2026 report put Gibson Dunn profits per equity partner at $8.890 million, Quinn Emanuel at $9.545 million and Milbank at $7.620 million, against the Am Law 100 average of $3.59 million. Law.com reported on 3 June 2026 that more partners than ever were reaching around $40 million including bonuses. Those are equity-partner averages and an extreme, not a white-collar W-2. A head of talent at an Am Law investigations platform told Sartori they matched the June 2026 scale because litigation boutiques were already posting it, not because 2025 FCPA collections recovered.
The general counsel pays twice: the salary, then the invoice.
Company revenue is the in-house pay driver. Specialty premia show up at the individual-contributor rung. The investigations AGC is the seat that buys Corporate Enforcement Policy optionality; it does not retire the Am Law panel.
Company size moves the in-house number more than title does. Chief legal officers at companies with revenue above $5 billion earn 44 percent more median base and 173 percent more total target compensation than chief legal officers at companies under $1 billion, per the same ACC 2025 summary. Associate general counsel at large companies: 36 percent more base, 75 percent more total. Attorney: 27 percent more base, 35 percent more total. Short-term incentive eligibility runs from 83 percent at Attorney to 96 percent at general counsel / chief legal officer and deputy general counsel, so the cash conversation at those titles is a target, not a salary. A general counsel at a sub-billion issuer who copies a $5 billion peer’s AGC band is not matching market. She is overpaying a different product.
Where the seat sits inside the company decides which of those premia you actually pay. ACC’s 2025 job-family groupings place investigations work in two places: the legal-specialty associate general counsel and expert-attorney track, where specialty pay is most visible, and the general counsel / deputy / AGC management track, where specialty fades and company size dominates. The chief compliance officer is a separate executive. ACC Jobline, 10 July 2026, distinguishes compliance counsel — a practicing lawyer on statutes, privilege and investigations — from the chief compliance officer, who owns the program and reports to the general counsel, the chief executive or the board.
The Department-wide Corporate Enforcement Policy of 10 March 2026 is why that interface is a hiring reason. Voluntary self-disclosure, cooperation and remediation now travel across components. The company that pays an AGC Investigations seat is buying the option to walk Path 1 (declination) or Path 2 (a near-miss non-prosecution agreement of fewer than three years, no monitor, a discretionary 50 to 75 percent reduction off the low end of the fine range, narrowed from a fixed 75 percent in the May 2025 Criminal Division version, as Mondaq reported on 22 July 2026). The first resolution under the new policy was a 19 March 2026 declination of a French medical-device company with about $1.2 million in disgorgement. Corporate cooperation does not buy peace for officers: the Fraud Division’s 29 July 2026 healthcare declination, reported by NYU/Debevoise and King & Spalding, declined to prosecute the company and still indicted the former chief executive on seven counts.
A general counsel at a healthcare issuer with revenue above $5 billion told us the 2026 outside-counsel invoice for healthcare-fraud defense now exceeds the fully loaded cost of the AGC Investigations seat, and the company still cannot drop the Am Law firm. That is the honest budget: internal cash at the ACC band, plus trial counsel in the districts the 23 June 2026 takedown actually used. For the broader in-house ladder, see US in-house counsel salary in 2026 and general counsel and chief legal officer pay.
The in-house hire buys optionality. It does not retire trial counsel.
Two seats. Three payers. One closed loop.
The public employer pays General Schedule cash and produces the credential. The firm pays lockstep and PEP. The company pays ACC cash plus equity, and still writes the firm a check.
Public credentialPrivate paycheck
- The public buyer Department of Justice, United States Attorney’s Offices, remaining Securities and Exchange Commission enforcement. Pays GS or SE scale. Supplies the former prosecutor the other two bid for.
- The firm buyer Am Law full-service White Collar and Investigations groups, and a thickening belt of Washington and New York litigation boutiques. Pays the 2026 lockstep and funds partner cash from firm-wide profits.
- The company buyer Public-company legal departments, especially at issuers above $5 billion in healthcare, financial services, energy, imports and government contracting. Pays ACC cash and LTI, and retains the firm.
The Bureau of Labor Statistics Occupational Outlook Handbook, visited 27 August 2026, puts 52 percent of 863,700 lawyer jobs in 2025 in legal services, 11 percent in self-employment, 8 percent in local government, 7 percent in state government and 5 percent in federal government. Corporate counsel work for a single organization and advise executives; criminal-defense and investigations work sits inside legal-services firms. That split is the pay table: lockstep at the firm, ACC title medians in-house, GS-14/15 at the Department of Justice.
On the firm side the branded product is White Collar Defense and Investigations, Internal Investigations, Anti-Corruption and FCPA, Securities Enforcement, Healthcare Fraud, Trade and Customs Fraud, Sanctions and Export, False Claims Act and qui tam. Gibson Dunn’s practice page, accessed 2026, states the group includes more than 80 former prosecutors and high-level government officials, has conducted FCPA investigations in over 80 countries, and was ranked number one on the Global Investigations Review 30 for eight consecutive years, the accolade dated 14 November 2025. Katten Muchin Rosenman’s White Collar and Internal Investigations page, current as of 10 September 2026, publishes the alumni composition without names: 13 former federal or state prosecutors, 11 former assistant US attorneys, five former SEC counsel, three former CFTC counsel. Chambers USA listings on that page cover Illinois, Texas and New York (Highly Regarded) for White-Collar Crime and Government Investigations in 2026. Those are landscape facts, not a census of every platform that pays the scale.
On the company side the industries that actually retain this work are the ones on the 2026 charging calendar: financial institutions (insider trading, benchmarks, anti-money-laundering, Office of Foreign Assets Control); healthcare and life sciences (Anti-Kickback, Food and Drug Administration, False Claims Act); energy and industrials (environmental crimes, extractives FCPA); importers and manufacturers (customs, Section 301, forced labor); government contractors (procurement fraud, now a Fraud Division critical priority); issuers facing accounting inquiries; technology and crypto. Private-equity sponsors of healthcare, government-contractor and importer portfolio companies are a minority buyer — portfolio-company general counsel plus sponsor-level risk — not the primary 2026 payer.
The public side is being rebuilt as two desks. The Criminal Division Fraud Section was rebranded the White Collar and Corporate Enforcement Section and keeps FCPA, securities, market and private fraud, health and safety, and the Corporate Enforcement and Compliance Unit. The National Fraud Enforcement Division, final rule 18 August 2026, effective 24 August 2026, takes taxpayer-program fraud: procurement, healthcare, tax, trade and customs, corporate misconduct against the fisc, targeting about 500 attorneys and staff. United States Attorney’s Offices remain the geographic buyer — 56 districts in the 23 June 2026 healthcare takedown. The Securities and Exchange Commission’s specialized FCPA Unit no longer appears in SEC directories, per Gibson Dunn on 8 January 2026. Alumni leaked to the private buyers. Sartori maps approximately 67,000 lawyers in New York; that file records admission and employer, not which of the three payers currently holds the person.
| Buyer | Who earns | Who pays | 2026 pressure |
|---|---|---|---|
| Am Law firm or investigations boutique | Lockstep associate; investigations partner at the PEP average | The firm, from firm-wide utilization, not from the FCPA penalty line | June 2026 scale match; litigation boutiques moving first |
| Public-company legal department | Attorney through GC/CLO; AGC Investigations; CCO as a parallel executive | The company, in cash plus STI and LTI; the GC also pays the outside-counsel invoice | CEP disclosure routing; healthcare, trade and sanctions dockets |
| DOJ, USAO, remaining SEC enforcement | Trial Attorney, AUSA, Enforcement counsel — the credential, not the private figure | The public fisc, on the General Schedule | FCPA Unit restock against a thinner unit; Fraud Division standing up |
FCPA collections fell. The rest of the docket did not.
A general counsel who staffs 2026 as if the statute had been repealed will be short a healthcare-fraud lawyer, a trade-fraud lawyer, and a disclosure desk that knows which component to call.
PauseRebuild
- Pause New FCPA matters freeze. Existing indictments go to case-by-case review. The SEC says it will follow the Department of Justice.
- Filter Guidelines restart the statute against cartel nexus, US economic injury, national security and individual corrupt intent. Assistant Attorney General authorization sits on every new matter.
- Pivot December conference language: a pivot, not a sea change. A Department-wide disclosure policy is previewed so outcomes do not depend on which prosecutor holds the file.
- Rebuild Corporate Enforcement Policy goes Department-wide. A National Fraud Enforcement Division takes the public fisc. Healthcare and trade fraud supply the volume the filtered FCPA docket no longer does.
Gibson Dunn’s 8 January 2026 year-end FCPA update is the document that still prices FCPA cash, and it is a document of contraction. After the guidelines, defense counsel received continue-or-terminate calls with no detailed reasoning. Public 2025 corporate FCPA ran to three Department of Justice actions and about $123 million, of which the 10 November 2025 TIGO Guatemala / Millicom deferred prosecution agreement — $118.2 million in fines and forfeiture, a cartel factor via narcotrafficking cash in the bribe stream, a 50 percent Guidelines discount, a two-year DPA, no monitor — was roughly 96 percent of the year’s corporate dollars. Liberty Mutual on 7 August 2025 was a declination with $4.7 million disgorgement, the first test of the May Corporate Enforcement Policy. Smartmatic on 16 October 2025 was the first corporate FCPA indictment in 15 years. The Securities and Exchange Commission recorded zero FCPA actions in 2025; the FCPA Unit Chief retired in April 2025 and was not replaced.
That is a measured drop in announced FCPA cash, not a measured drop in defense hours. Alston & Bird, writing on 10 December 2025 from the American Conference Institute FCPA conference, recorded Deputy Attorney General Blanche reaffirming enforcement against schemes with meaningful US ties, and then-Acting Assistant Attorney General Galeotti describing a “pivot” rather than a “sea change.” Limitations periods outlast a single administration. The UK Serious Fraud Office, the Swiss Office of the Attorney General and the French Parquet National Financier announced an International Anti-Corruption Prosecutorial Taskforce on 20 March 2025; that is a one-line contrast, not a second market. The Foreign Extortion Prevention Technical Corrections Act, 18 U.S.C. § 1352, has been on the books since July 2024 and, as of Gibson Dunn’s 8 January 2026 update, had yet to produce a standalone prosecution. FEPA literacy is a 2026 add-on for FCPA partners, not a staffing line.
Monitor hours are the one white-collar product that did shrink on the 2025 plan. Then-Acting Assistant Attorney General Matthew Galeotti’s 12 May 2025 white-collar enforcement plan revised the Corporate Enforcement Policy, announced a review of active corporate resolutions for early termination of reporting, and amended monitorship guidance. Public early terminations in 2025 FCPA-related resolutions included Glencore on 20 March 2025 (15 months early), Stericycle on 21 April 2025 (7 months early), Albemarle on 1 May 2025 (17 months early), ABB on 18 June 2025 (6 months early) and Honeywell UOP on 8 July 2025 (5 months early). The hiring consequence is fewer multi-year monitor staffs and faster two-year deferred prosecution agreements, not a disappearance of disclosure work. Jenner recorded two FCPA trials in 2025, both wins, and one corporate FCPA indictment after a 15-year hiatus. Trial-ready counsel in the Southern District of Texas, the Southern District of Florida, the Western District of Pennsylvania and the Eastern District of New York still had a 2025 docket. The dismissed New Jersey Cognizant-related indictment — the Department first said it would proceed after the Executive Order, then moved to dismiss, with the court granting on 3 April 2025 and the SEC dismissing the parallel civil case on 15 July 2025 — is the anecdote that the pause had teeth. Do not staff a 2026 investigations desk as if every 2024 monitor were still running, and do not staff it as if trials had stopped.
The volume moved. Jenner & Block, on 29 January 2026, reading the Fraud Section 2025 Year-in-Review, put the Section at over 200 prosecutors, up 30 percent from about 150 at the end of 2024, with aggregate intended fraud loss over $16 billion and 15 corporate enforcement actions. The 23 June 2026 healthcare takedown charged 455 defendants, including 90 licensed medical professionals, across 45 states and territories and all 50 state Medicaid Fraud Control Units, with more than $182 million in assets seized; the Centers for Medicare & Medicaid Services suspended 1,079 providers and revoked 1,403. Medicaid: 295 defendants, over $518 million in false claims. The Trade Fraud Task Force, launched August 2025 as a Department of Justice–Department of Homeland Security effort, had surpassed $1 billion in recoveries, penalties, forfeiture and publicly charged losses by 14 July 2026, per King & Spalding on 9 September 2026. The headline civil number in the first half of 2026 was the 12 May 2026 Perfectus Aluminum False Claims Act settlement of $549.5 million for antidumping and countervailing-duty evasion on Chinese aluminum extrusions.
National Security Division work folded into the same disclosure logic. Mondaq recorded on 22 July 2026 that NSD’s first Corporate Enforcement Policy declination, Robert Bosch GmbH on 17 June 2026, concerned Entity List exports by two non-US subsidiaries, with a parallel Bureau of Industry and Security penalty of about $36 million. Sanctions and export counsel became white-collar-adjacent hires. CFIUS civil penalties rose from $250,000 to $5 million under an 18 November 2024 final rule; that tightening is named here as a neighboring pressure on the same general-counsel budget, not as a CFIUS treatise. Demand for the investigations bench, as opposed to what it pays, belongs to white-collar demand driven by enforcement and geopolitics.
The requisition freezes. The shortlist does not.
Sartori & Partners has worked the New York market for more than 10 years, for public-company general counsel and for Am Law investigations groups, inside a global research program of nearly 1.5 million mapped lawyer profiles and quarterly surveys since 2019. Over the trailing three years we closed 33 associate searches, with a 93 percent completion rate and a typical timeline of 6 to 12 weeks.
Of those 33 closed New York associate searches over three years, 11 were white-collar, investigations or enforcement-adjacent associate seats: 7 at law-firm platforms and 4 in-house attorney or senior-attorney investigations seats. New York associate-line counter-offer incidence is 37 percent. Among those 11 white-collar files, 4 drew a counter-offer; 2 of those 4 still departed after the 11-working-day median acceptance window. Sartori’s quarterly survey since 2019, read against the same New York cohort, found that 38 of 67 in-house respondents sitting inside investigations or compliance desks over the 2026 survey window said their board had reallocated 2026 legal-budget growth from FCPA monitorships toward healthcare, trade-fraud or sanctions coverage.
The number that does not flatter the method: 4 of those 11 white-collar associate files stalled past twelve weeks, not on candidate scarcity, but because the general counsel froze the requisition while the 2025 FCPA pause and the March 2026 Corporate Enforcement Policy rewrite were still being briefed to the board. We completed 93 percent of the 33-file book. This is the segment that ran long. A search that opens before the company has decided whether the seat is FCPA, healthcare fraud, trade fraud, or a disclosure-routing AGC is not a search. It is a committee waiting for a memorandum.
Three composite files
A public-company healthcare issuer, revenue above $5 billion, asked us to fill an Associate General Counsel, Investigations seat after the 23 June 2026 takedown landed in two of its districts. The brief named False Claims Act, Anti-Kickback and a board-level disclosure question under the new Corporate Enforcement Policy. We closed in 9 weeks, inside the 6-to-12-week band, against a counter-offer from the incumbent Am Law panel that wanted to keep the work. The general counsel kept both: the AGC, and the firm.
An Am Law 50 white-collar group asked for a fourth-year associate with a United States Attorney’s Office tour and a live trial seat. The June 2026 scale match had already reset the conversation; a litigation boutique in the same city was posting the new ladder. We closed in 8 weeks. Book verification was not the issue. Conflicts screening against a pending healthcare-fraud co-counseling relationship was. The file is one of the 7 firm-side seats in the 11-file cut.
A public-company importer asked for a Senior Attorney to own origin, Harmonized Tariff Schedule and False Claims Act exposure after the Perfectus settlement. The requisition opened, froze for six weeks while the chief legal officer and the board argued whether a criminal disclosure belonged with the Criminal Division, the Fraud Division or the National Security Division, and then reopened as an AGC Trade and Sanctions seat. Elapsed time 14 weeks. That is one of the 4 files that ran past twelve weeks. The candidate pool was never the constraint.
For companies building the function rather than adding a specialist, the first-chair question is separate: hiring your first general counsel. For the associate-line search itself, see associate recruiting and in-house counsel recruiting.
White-collar attorney pay in 2026: common questions
What is a 2026 white collar lawyer salary at a US law firm versus in-house?
On the 2026 Milbank lockstep a first-year base is $235,000 and an eighth-year base is $455,000, effective 1 July 2026. In-house, the Association of Corporate Counsel’s March 2025 medians run from a $148,000 attorney base to a $330,000 general counsel / chief legal officer base, with median total target direct compensation of $503,000 at the GC/CLO seat. There is no published white-collar-only cut of either series. A white-collar associate at a matching firm earns the same lockstep as a corporate associate; the in-house nearest published proxy for enforcement-adjacent work is ACC’s securities, antitrust and bankruptcy specialty ranking.
Did the 2025 FCPA pause cut what companies pay investigations counsel in 2026?
No published in-house survey isolates an FCPA-pause discount; ACC’s March 2025 title medians still govern the 2026 in-house conversation. Corporate FCPA collections fell to about $123 million across three Department of Justice actions in 2025, against $1.28 billion across eleven core actions in 2024, per Gibson Dunn’s 8 January 2026 year-end update, and the SEC recorded zero FCPA actions in 2025. The same year the Fraud Section charged a record $16 billion in intended fraud loss, and the 23 June 2026 healthcare takedown alleged $6.5 billion in false claims. General counsel who froze an FCPA requisition still paid healthcare, trade-fraud and sanctions seats.
How much should a general counsel budget for an investigations AGC versus outside counsel?
Budget the ACC Associate General Counsel median of $245,000 base and $294,000 total cash (effective 1 March 2025), then add the Am Law invoice on top. Median total target at that title, including long-term incentive, is $338,000, and 59 percent of AGCs are LTI-eligible. A general counsel at a healthcare issuer with revenue above $5 billion told Sartori the 2026 outside-counsel invoice for healthcare-fraud defense now exceeds the fully loaded cost of the AGC Investigations seat — and the company still cannot drop the firm. The in-house hire buys CEP optionality and a named signer; it does not replace trial counsel in 56 districts.
What does a DOJ FCPA trial attorney earn compared with the 2026 lockstep?
A Trial Attorney in the FCPA or Market, Government and Consumer Fraud Units was posted at GS-14/15, $143,913 to $197,200, on USAJOBS from 23 June to 17 July 2026. That cap sits below the $235,000 first-year lockstep that took effect 1 July 2026. The public seat is the credential the private buyers bid for, not the 2026 private figure. Gibson Dunn, Jenner and NYU/Debevoise do not agree on FCPA Unit headcount; treat 2025 staffing as a range from roughly a dozen to 22, against 32 at the end of 2024 in the Fraud Section year-in-review.
How long does a New York white-collar associate search take to close?
Sartori’s New York associate desk works to a typical 6 to 12 week timeline, with a 93 percent completion rate across 33 closed associate searches over three years. Of those 33 files, 11 were white-collar, investigations or enforcement-adjacent associate seats. Four of those 11 stalled past twelve weeks because the general counsel froze the requisition while the 2025 FCPA pause and the March 2026 Corporate Enforcement Policy rewrite were still being briefed to the board. Median offer-to-acceptance on the New York associate line is 11 working days; counter-offer incidence is 37 percent.
Should we staff FCPA, healthcare fraud or trade fraud in-house in 2026?
Staff the docket that is live, not the statute that was paused. FCPA work resumed on 9 June 2025 under four US-interest factors and Assistant Attorney General authorization; it did not resume at 2024 volume. Healthcare fraud produced 455 defendants and $6.5 billion in alleged false claims on 23 June 2026. The Trade Fraud Task Force had passed $1 billion in recoveries, penalties, forfeiture and publicly charged losses by 14 July 2026. A company with both a government-contracts exposure and a foreign-bribery angle may face two Department of Justice components on one set of facts. That routing question is an associate-general-counsel skill, not a first-year document-review skill.
Dockets, surveys, published scales and the New York research program.
The cash cells come from firm announcements, NALP, ACC, the Bureau of Labor Statistics, USAJOBS and the Am Law 100. The calendar cells come from Executive Order 14209, the Blanche guidelines, Department of Justice press releases and the 2025 FCPA year-end updates. New York interview and mandate figures come from Sartori's own research program.
Statutes, dockets, surveys and published scales
33 references- Sartori & Partners — New York Legal Talent Research Programme (1,675 structured interviews; ~67,000 lawyers mapped; quarterly surveys since 2019; mandate telemetry) sartoriglobal.com ↗
- Bloomberg Law — Milbank, McDermott Raise Associate Salaries Up to $455,000 (2 June 2026) news.bloomberglaw.com ↗
- Above the Law — ALERT: Milbank Does It Again - Associate Salaries Are Going Up!!! (2 June 2026) abovethelaw.com ↗
- Biglaw Investor — Biglaw Salary Scale + Bonuses (1968 - 2026) biglawinvestor.com ↗
- Above the Law — Cravath Starts Biglaw's Bonus Season With Year-End And Special Bonuses! (18 November 2025) abovethelaw.com ↗
- Global Legal Post — Raft of Big Law firms line up to match pacesetter Cravath’s associate bonuses (25 November 2025) globallegalpost.com ↗
- Bloomberg Law — Latest Associate Pay Raises Reflect Start of ‘Prestige Law’ Era (17 June 2026) news.bloomberglaw.com ↗
- Above the Law — A Five-Month-Old Firm Just Matched The Milbank Scale (8 September 2026) abovethelaw.com ↗
- NALP — Despite Expectations, $225,000 Entry Associate Salaries Lag at Large Law Firms (28 May 2025) nalp.org ↗
- ACC / Empsight — 2025 Law Department Compensation Survey EXECUTIVE SUMMARY acc.com ↗
- ACC Corporate Counsel Now — Does Your Background Pay Off? How Law School, Firm Experience, and Specialization Impact In-house Compensation (16 September 2025) corporatecounselnow.com ↗
- U.S. Bureau of Labor Statistics — Lawyers : Occupational Outlook Handbook (last modified 27 August 2026) bls.gov ↗
- The American Lawyer — The 2026 Am Law 100 law.com ↗
- The American Lawyer — The 2026 Am Law 100: Ranked by Profits Per Equity Partner (14 April 2026) law.com ↗
- The American Lawyer — As Top Partner Pay Eclipses $40M, Law Firms Increase Bonus Pools, Decrease Transparency (3 June 2026) law.com ↗
- The American Lawyer — Big Law Firms See 'Rare' Demand Growth, but Expenses Accelerate (17 August 2026) law.com ↗
- Gibson Dunn — 2025 Year-End FCPA Update (8 January 2026) gibsondunn.com ↗
- Jenner & Block — DOJ Fraud Section 2025 Year-in-Review (29 January 2026) jenner.com ↗
- Alston & Bird — DOJ Floods ACI FCPA Conference & Previews Enforcement in 2026 (10 December 2025) alston.com ↗
- White House — Pausing Foreign Corrupt Practices Act Enforcement to Further American Economic and National Security (Executive Order 14209, 10 February 2025) whitehouse.gov ↗
- U.S. Department of Justice — Guidelines for Investigations and Enforcement of the Foreign Corrupt Practices Act (FCPA) (9 June 2025) justice.gov ↗
- U.S. Department of Justice — Department of Justice Releases First-Ever Corporate Enforcement Policy for All Criminal Cases (10 March 2026) justice.gov ↗
- U.S. Department of Justice — National Health Care Fraud Takedown Results in 455 Defendants Charged in Connection with Over $6.5 Billion in Alleged False Claims (23 June 2026) justice.gov ↗
- USAJOBS — Trial Attorney (MGC & FCPA Units), announcement 26-CRM-FRD-025 (23 June–17 July 2026) usajobs.gov ↗
- U.S. Office of Personnel Management — Salary Table 2026-DCB opm.gov ↗
- Mondaq — 2026 Mid-Year Update On DOJ Corporate And White Collar Enforcement (22 July 2026) mondaq.com ↗
- King & Spalding — DOJ’s National Fraud Enforcement Division Is Open for Business (9 September 2026) kslaw.com ↗
- NYU Program on Corporate Compliance and Enforcement — Compliance and Enforcement (Debevoise on the Fraud Division, August/September 2026) wp.nyu.edu ↗
- U.S. Department of Justice — White Collar and Corporate Enforcement Section justice.gov ↗
- U.S. Department of Justice — Foreign Corrupt Practices Act Unit (updated 18 August 2026) justice.gov ↗
- Gibson Dunn — White Collar Defense and Investigations gibsondunn.com ↗
- Gibson Dunn — GIR Ranks Gibson Dunn No. 1 Among World’s Best Investigations Practices 2025 (14 November 2025) gibsondunn.com ↗
- Katten Muchin Rosenman — White Collar and Internal Investigations katten.com ↗
ACC title medians measure self-reported in-house cash by title, not a white-collar-only cut. The Milbank ladder is the matching-firm associate scale, not an investigations premium. Am Law profits per equity partner are firm-wide averages. FCPA Unit headcount is cited as a range across Gibson Dunn, Jenner and NYU/Debevoise. Sartori mandate counts sit inside 33 closed New York associate searches over three years; interview segments sit inside 1,675 structured interviews.
Keep reading
White-collar demand, enforcement and geopolitics
The demand-side companion: who is hiring investigations benches, and why. This salary page does not retell that market.
Read the demand map SalaryUS in-house counsel salary 2026
The broader in-house ladder this white-collar cut sits on — title medians, company size and the equity tail.
Read the in-house benchmark SalaryBigLaw associate salary scale 2026
The full class-year lockstep behind the firm-side cells — $235,000 to $455,000, effective 1 July 2026.
Read the 2026 scalePrice the seat before you post it
Hire the investigations lawyer the 2026 docket actually requires.
Whether you are a general counsel staffing an AGC Investigations seat or a chief legal officer rewriting the outside-counsel panel after the Corporate Enforcement Policy, we map the field and close the search on a 6-to-12-week clock.