By Richard Ben-Veniste, a senior partner in the Washington, D.C. office of the law firm Mayer, Brown, Rowe & Maw LLP, specializing in white collar defense and civil litigation. Mr. Ben-Veniste formerly served as Chief of the Special Prosecutions Section of the U.S. Attorney’s Office for the Southern District of New York, and was a member of the National Commission on Terrorist Attacks Upon the United States (“9/11 Commission”); and Raj De, an associate with the firm, and former Counsel to the 9/11 Commission.