Securities & Regulatory Enforcement

With unprecedented resources, the Securities and Exchange Commission (SEC), the Commodity Futures Trading Commission (CFTC), the Department of Justice (DOJ), and other marketplace watchdogs have vigorously pursued actions against financial services and investment firms and their owners, managers, and employees. These federal agencies often use the home-court advantage of administrative proceedings to seek various tough sanctions. Even in the most complex, high-profile, and contested matters, we have repeatedly managed to exonerate — or effect better outcomes — for our clients.

WMH lawyers have counseled corporate clients on an array of regulatory and compliance issues. We have designed and implemented compliance programs addressing anti-money laundering, Foreign Corrupt Practices Act (FCPA), antitrust, political contributions, and other regulatory issues.

Representative Cases

  • Represent the Chief Accounting Officer at a large regional bank, in a SEC investigation involving allegations of accounting violations.
  • Represent the former Chief Financial Officer of a New York-based hedge fund in connection with securities fraud charges by the United State’s Attorney’s Office and the SEC.
  • Represent a manager of trading desks who is under investigation by the SEC for internationally failing to comply with terms of pre-release agreements between certain U.S. banks and ADR broker firms. The Antitrust Division of U.S. DOJ has initiated a related investigation to determine whether there is collusion between various ADR broker firms.
  • Represent the former head of interest rate swap trading at a major multinational bank, as a third-party witness, in connection with private antitrust claims alleging that derivatives dealers colluded to restrain competition in the swap market.
  • Represented the former General Counsel of a major New York and New Jersey public benefit corporation in parallel SEC and state grand jury investigations into allegations of federal securities fraud and violations of New York’s Martin Act. The SEC and the New York County District Attorney’s Office each closed their inquiries without filing charges.
  • Represented a prominent video game company in connection with due diligence on a licensing agreement in China.
  • Represented an associate portfolio manager at a leading multi-fund investment manager in an investigation by the Division of Enforcement of the SEC into alleged mismarking of assets. After hearing presentation from WMH, the SEC declined to pursue any action against our client.
  • Represented a real-estate investment firm in an investigation of its business practices by the Division of Enforcement of the SEC. The SEC concluded investigation without pursuing any action against our client.
  • Over the course of a number of years, WMH has represented a U.S.-based multinational investment bank and financial services company and its employees in a variety of regulatory and government investigations, including in investigations by the DOJ, the SEC, FINRA and other state regulators and enforcement agencies.
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