Compliance & Rules.
Enforcement defense before the regulators decide.
The work — Government investigations and enforcement defense. SEC, DOJ Fraud Section, FTC, CFIUS, OFAC, and parallel international inquiries. We engage early — the months before the first subpoena are where the case is decided.
What we cover — SEC enforcement on securities, accounting, and disclosure matters. DOJ Fraud Section grand-jury defense for officers and entities. CFIUS and national-security review. FCPA, OFAC sanctions, and export control. Coordinated defense across the SEC, DOJ, and overseas regulators.
How we work — A privileged internal review under a non-waiver protocol is the foundation. We engage regulators on a single, transparent factual record — the goal is to shape the charging theory before it ossifies. Officers and directors get personal counsel from the first hint of a parallel proceeding.
Recent matter — The former CEO of a NYSE-listed software company in a parallel SEC and DOJ investigation into revenue recognition. DOJ declined to prosecute. SEC settled on no-fraud terms. No officer-and-director bar. No admissions required.
