Christopher Wray, of King & Spalding. (Photo: Alison Church/ALM)
Christopher Wray, the King & Spalding white-collar partner who was nominated to replace fired FBI director James Comey, reported earning $9.2 million in his partnership share from 2016 and so far this year, according to financial documents made available Monday.
Wray, a King & Spalding partner for nearly 12 years in the firm’s Washington and Atlanta offices, revealed numerous big-name clients in the required disclosure, released by the U.S. Office of Government Ethics. Wray is set to appear Wednesday at the U.S. Senate Judiciary Committee for his confirmation hearing.
Wray said in his U.S. Senate questionnaire he expects to receive a King & Spalding estimated partnership distribution of $880,000 on July 17. He said that he would receive an estimated $815,000 partnership share if he continued as a partner at the firm for the entire month of July.
Those figures, divided into the $9.2 million yearly paycheck Wray reported, likely have come as part of his monthly draws over 18 months and from his profit 2016 distribution. Still, at that amount, Wray would be one of the richer-through-compensation law firm partners to enter the Trump administration—or any administration.
He also said he anticipated receiving $1.27 million at the time he withdraws from King & Spalding partnership, marking the full return of his paid-in capital from the firm.
Wray said he performed legal services for, among other companies, Johnson & Johnson, Wells Fargo & Co., Draftkings Inc. and FanDuel Inc., Chevron Corp. and Credit Suisse Group. Wray also noted he provided legal services to New Jersey Gov. Chris Christie. Wray listed three confidential clients whose identities he said he could not disclose.
Wray’s client list and his tenure in Big Law could come into sharper focus at his confirmation hearing. Wray is expected to face questions about whether and how he will retain his independence as the White House faces mounting scrutiny over Russia’s interference with the 2016 presidential election. President Donald Trump reportedly demanded loyalty from Comey before ultimately firing him over his role in leading the investigation of Russia’s meddling in the election.
CNN last month reported that a reference to a case involving a Russian investigation—targeting one of Wray’s American clients—was removed this year from Wray’s King & Spalding biography page. That client was not disclosed on Wray’s form released Monday.
“Chris made this change to his bio, along with other minor tweaks, in an attempt to make the material more current. At the time he made the adjustments—January 12, 2017—he was not being considered for, and did not anticipate being nominated for, FBI Director, or any position in government,” a King & Spalding spokesperson told CNN.
Wray has deep ties to the Justice Department as a former assistant U.S. attorney general and, later, as part of the top brass at Main Justice in Washington.
He was one of the youngest appointees to lead the Justice Department’s Criminal Division. He served from September 2003 to May 2005 during the George W. Bush administration. That tenure coincided with Comey’s stint as deputy attorney general following the departure of Wray’s mentor Larry Thompson from the DAG’s office.
Earlier, Wray was a King & Spalding associate from 1993 to 1997, when he joined the U.S. Attorney’s Office for the Northern District of Georgia.
Wray, if he’s confirmed, agreed not to receive a King & Spalding bonus, severance payment or any contingency fee recoveries from the firm, according to the terms of his ethics agreement. For one year after he resigns from King & Spalding, Wray is prohibited from “personally and substantially” participating in any matter that involves a client of the firm, according to the document, which was released Monday.
Wray agreed in his ethics pledge to divest his interests in more than 400 companies in industries that include banking and finance, insurance, telecommunications, pharmaceuticals, health care, energy and manufacturing. Many of those shares are worth between $1,000 and $15,000, he disclosed. He cannot participate in any matter that involves those companies until he has divested his interest, or he has received a written waiver.
If confirmed, Wray wouldn’t be the first King & Spalding partner to join the Trump administration. Two others come from the firm’s trade practice, which is known for representing American interests in anti-dumping trade cases aimed at China. Stephen Vaughn resigned from the firm in January to work in the office of the U.S. Trade Representative, where he is now general counsel. Gil Kaplan, who is still at the firm, is the nominee for Commerce Under Secretary for International Trade.
For comparison with Wray’s $9.2 million partnership share, Kaplan told the Office of Government Ethics in March that his share at King & Spalding earned him just over $1 million.
Bobby Burchfield, a King & Spalding partner in D.C., serves as the outside ethics counsel for the Trump companies’ trust. Trump’s personal tax lawyers at Morgan, Lewis & Bockius created Burchfield’s position this year as part of an attempt to shield the president from conflicts of interest.
When Trump announced Wray as his intended nominee for FBI Director, Burchfield told The National Law Journal the two law partners had not worked together on matters regarding the Trump organization.