SEC Investigations and Enforcement Actions

Our approach is grounded in early strategic intervention, disciplined risk assessment, and credibility with regulators. In many matters, the objective is to resolve investigations before charges are filed. Where enforcement proceedings move forward, we prepare cases with the expectation that they may be litigated, and we are prepared to try them.

Clients include senior executives, traders, investment professionals, compliance officers, and financial institutions navigating high-stakes regulatory scrutiny.

SEC Civil Investigations

We represent clients in SEC inquiries and formal investigations involving trading practices, disclosure issues, accounting judgments, fiduciary duties, and sales practices. Our work frequently focuses on shaping a fair factual record early, managing regulator interactions, and positioning matters for favorable resolution without charges.

Representative matters include:

• Investment bankers, traders, hedge fund analysts, and senior investment professionals in SEC investigations where no charges were brought.
• Financial executives investigated for disclosure, accounting, and trading practices with investigations closed or resolved on favorable terms.

Parallel and Coordinated Criminal Exposure

Many SEC investigations unfold alongside criminal inquiries by the Department of Justice or other authorities. We regularly coordinate strategy across civil and criminal forums, sequencing decisions to protect clients’ legal and reputational interests.

Representative matters include:

• Traders and bankers subject to parallel SEC and criminal investigations with no charges filed.
• Investment professionals facing SEC scrutiny alongside related civil or criminal proceedings that were dismissed or resolved confidentially.

SEC Administrative Proceedings and Trials

Where the SEC initiates enforcement proceedings, including administrative actions, we prepare matters with a trial-ready posture. Our litigation experience informs both defensive strategy and settlement posture.

Representative matters include:

• A private equity fund and its chief executive in SEC proceedings concerning accounting and reporting issues, resulting in a complete trial victory.
• Senior executives in SEC enforcement proceedings involving investment products and fund management, resolved on favorable terms.

Strategic Early-Stage Engagement

In many matters, the most consequential decisions are made before an investigation becomes public or formalized. We advise clients at the earliest stages of regulatory risk, including internal reviews, document strategy, and engagement with regulators.

Representative matters include:

• Compliance officers, CFOs, COOs, and investment management heads advised during early-stage SEC inquiries that concluded without enforcement action.
• Professionals investigated for technical accounting or sales-practice issues where early intervention avoided formal proceedings.

Other SEC and Enforcement Matters Include

• RMBS trader in criminal and SEC investigation; no charges brought
• Investment banker in SEC investigation; no charges brought and related civil suit resolved confidentially
• Technology professional in SEC investigation of trading commissions; no charges brought
• GICs bankers in SEC and criminal investigations; no charges brought and civil suits resolved
• CFO and COO of investment adviser/broker-dealer in SEC investigation of disclosures and trading practices; no charges brought
• Private equity fund and CEO in SEC proceedings concerning accounting and reporting; complete trial victory
• EVP of national investment manager in SEC proceedings concerning bond fund; favorable resolution
• Hedge fund analyst in SEC investigation; no charges brought and civil suits dismissed
• Head of investment management at bank in SEC investigation concerning sales practices; no charges brought
• Actuary in SEC investigation involving accounting for insurance contracts; no charges brought