People

Christopher Davies

Partner

Vice Chair, Securities Department

Davies, Christopher

Christopher Davies has more than 15 years' experience representing clients in complex civil, criminal and administrative matters, often involving crisis management, including communications and public policy strategy and outreach.

Over the past year, Mr. Davies has represented, among others: a multinational bank in an investigation concerning its accounting for distressed assets; a number of clients in anti-corruption investigations; multiple US and non-US clients in proceedings before federal agencies; an Indian tribe in a membership dispute before the Department of the Interior; an entity subject to pending criminal and administrative investigations, as well as civil litigation, in Caribbean jurisdictions; and an organization in a multi-jurisdictional employment-related investigation and dispute in Europe. Mr. Davies has also conducted an internal investigation of alleged financial impropriety by an Indian tribe's senior leadership and another internal investigation concerning alleged illegality and related misrepresentations by a mortgage servicer.

Mr. Davies has extensive international experience and has represented non-US-based entities from countries including Australia, Canada, China, Germany, Hungary, India, Israel, Japan, the Netherlands, Russia, Sweden, Trinidad and Tobago, and the UK in connection with both US and non-US proceedings.

Government Investigations

Mr. Davies has represented clients before federal and state regulatory and law enforcement agencies, including the SEC, multiple US Attorneys' Offices and Main Justice. Investigations have concerned allegations of: securities, accounting, tax and other frauds; insider trading; corrupt payments; financial reporting and disclosure improprieties; noncompliance with professional and regulatory standards; environmental crimes; pretexting; anti-money laundering violations; and discriminatory conduct.

Internal Investigations

Mr. Davies has led and participated in internal investigations concerning: improper document destruction; misrepresentations; obstruction of government inquiries; potential corrupt payments; misappropriation of assets; misvaluation of securities and investments; discriminatory conduct and harassment; financial and tax fraud; non-compliance with legal and regulatory obligations; and insider trading.

Litigation

Mr. Davies has litigated cases in federal and state trial and appellate courts, including the Supreme Court. He has also advised clients on civil, administrative and criminal litigation in non-US jurisdictions. Matters have included: securities fraud, derivative actions, breaches of contract, unfair competition and other business torts; False Claims Act violations; discriminatory conduct; violations of professional standards; and breaches of duty.

Counseling

Mr. Davies counsels clients on: cross-border discovery; privilege matters; compliance and other risk management policies and practices; document retention protocols and practices; and regulatory and risk management matters.

Pro Bono

Mr. Davies has served as outside general counsel to a Washington DC-area private school for the past decade; represents indigent defendants in state criminal appeals; has recovered assets stolen from a nonprofit mental healthcare provider through litigation in DC courts; has represented a non-profit healthcare entity in private litigation and in a suit against the DC government; has sued Richmond for pervasive noncompliance with the Americans with Disabilities Act in its schools; has served as Complaint Examiner for DC Police Complaints Board; and has advised National Association of Criminal Defense Lawyers and filed briefs on NACDL's behalf concerning right to counsel and due process, expert testimony in financial fraud cases, attorney-client privilege, and structuring.

Mr. Davies is a vice chair of the firm's Securities Department. 

Honors & Awards

  • Selected by peers for inclusion in the 2013-2018 editions of the Best Lawyers in America for his work in securities/capital markets law. Clients say Mr. Davies is a “tremendous resource” and “exceptionally smart and pragmatic and always willing to go the extra mile.” This comment appears on the U.S. News & Best Lawyers “Best Law Firms” website at bestlawfirms.usnews.com.
  • Recognized nationally in the 2015, 2016 and 2017 editions of Chambers USA: America's Leading Lawyers for Business for his work in the securities regulation: enforcement area
  • Recommended by The Legal 500 United States for his securities litigation defense practce

Publications & News

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February 23, 2018

Supreme Court Articulates Dodd-Frank Whistleblower Definition in Digital Realty Trust, Inc. v. Somers

On February 21, 2018, the Supreme Court held in Digital Realty Trust, Inc. v. Somers that the anti-retaliation whistleblower protections under the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Dodd-Frank Act”) apply only to those who have reported allegations to the Securities and Exchange Commission (“SEC”) as of the time of the allegedly retaliatory conduct.

August 16, 2017

WilmerHale Lawyers Named Among the 2018 Best Lawyers in America®, Nine Recognized as Lawyers of the Year

Best Lawyers in America®—the oldest and most respected peer-review publication in the legal industry—recognizes 107 WilmerHale lawyers and names nine partners as Lawyers of the Year in its 24th edition.

June 9, 2017

The Legal 500 United States 2017 Recognizes 125 WilmerHale Lawyers Across 28 Practice Areas

The Legal 500 United States has released its 2017 rankings, recommending 125 WilmerHale lawyers—including 12 who are named to its elite “Leading Lawyers” list and two on its “Next Generation Lawyers” list—and 28 practice areas in its 11th edition.

May 26, 2017

WilmerHale Lawyers and Practices Recognized in 2017 Edition of Chambers USA

Chambers and Partners announced its rankings for the 2017 edition of Chambers USA: America's Leading Lawyers for Business, with WilmerHale listed among the nation's best in 50 practice area categories. Chambers also ranked 86 WilmerHale lawyers as leaders in their respective fields.

January 3, 2017

SEC Settles Two More Whistleblower Protection Cases

Continuing its efforts to bring enforcement actions for violations of whistleblower protections, the Securities and Exchange Commission recently settled two more cases. Both cases involved severance agreements that contained provisions that, the SEC asserted, expressly prohibited former employees from communicating with the government about possible violations of law. This WilmerHale Client Alert was republished by Law360.

October 31, 2016

SEC Examiners Focus on Investment Adviser and Broker-Dealer Compliance With Whistleblower Rules

Last week, the SEC's Office of Compliance Inspections and Examinations (OCIE) issued a Risk Alert regarding examinations of investment adviser and broker-dealer registrants' compliance with key whistleblower provisions arising out of the Dodd-Frank Act.

October 11, 2016

New SEC Settlements Show Continued Focus on Whistleblower Protection and Severance Agreements

The Securities and Exchange Commission continues to pursue enforcement actions against companies for whistleblower-related violations. This WilmerHale Client Alert, which was also published by Bloomberg BNA's Securities Regulation & Law Report on December 5, 2016, examines the latest in a recent string of settled orders.

September 9, 2016

WilmerHale's FCPA Practice Lands GIR “Elite” Ranking

Global Investigations Review Just Anti-Corruption recently gave WilmerHale's Washington DC office an “elite” ranking for its Foreign Corrupt Practices Act (FCPA) practice, putting it among the top firms in the nation's capital.

August 15, 2016

WilmerHale Lawyers Named Among the 2017 Best Lawyers in America®, Six Recognized as Lawyers of the Year

Best Lawyers in America®—a respected peer-review publication in the legal industry—recognizes 101 WilmerHale lawyers and names six partners as Lawyers of the Year in its 23rd edition.

June 22, 2016

The Legal 500 United States 2016 Recognizes 111 WilmerHale Lawyers Across 30 Practice Areas

The guide's rankings are based on a series of criteria, including client feedback, interviews with private practice lawyers, and its own research.

Recent Highlights

Investigations

  • Represented entity in connection with criminal and administrative investigations in Trinidad and Tobago.
  • Conducted internal investigation for Indian tribe concerning allegations that ousted leadership had misappropriated tens of millions of dollars of tribal assets over 12 years.
  • Conducted internal investigation of mortgage servicer accused of violating its obligations to borrowers and then misrepresenting its compliance with relevant regulations and laws.
  • Represented client in federal criminal and administrative investigations, state investigations and civil litigation relating to insurance and accounting fraud.
  • Represented European client in multi-jurisdictional investigation and negotiated civil resolution arising from allegations of sexual assault by former senior corporate officer.
  • Represented US bank and its non-US parent in investigation arising from whistleblower complaint concerning alleged misaccounting for portfolio of bad mortgages.
  • Oversaw internal investigation in India concerning potential illicit payments to Indian tax authority on behalf of US, UK and other multi-national entities.
  • Represented major oil and gas company in Department of Justice and executive agency investigations arising from environmental disaster. Also advised on False Claims Act liability, debarment, indemnification and other aspects of case.
  • Represented auditor in India in connection with US investigations and litigation following revelation of largest fraud in Indian history. Advised client with respect to parallel Indian criminal, civil and regulatory proceedings.
  • Represented Pakistani entity in connection with allegations of fraud, corruption, and misconduct following failure of Kabul Bank.
  • Represented professional sports team owner in insider trading investigation.
  • Represented Russian entity in connection with global investigations and litigation arising from collapse of Yukos Oil following the arrest of Mikhail Khodorkovsky.
  • Represented entity in criminal and administrative investigations about finite reinsurance market.
  • Represented auditor in criminal and administrative investigations, as well as in parallel civil litigation, concerning channel stuffing and fraud by pharmaceuticals company.
  • Represented Fortune 50 CEO in insider trading investigation arising from purchases and sales of his own company’s securities through multiple accounts.
Litigation
  • Advised client on appellate brief filed in Philippines employment litigation.
  • Filed amicus brief with First Circuit arguing that SEC erred in application of materiality standard and rule of lenity, in enforcement action against individuals. (Flannery v. SEC, Nos. 15-1080, 15-1117 (1st Cir. 2015))
  • Represented Indian tribe before Department of the Interior, following remand of membership dispute by the District Court for the District of Columbia
  • Briefed and argued successful motion to dismiss on behalf of auditor defendant in securities class action. (Plumbers, Pipefitters, and NES Local Union No. 392 Pension Fund v. Fairfax Financial Holdings Ltd., No. 1:11-cv-05097-JFK (SDNY 2012))
  • Represented auditor in successful motion to dismiss in securities class action. (In re Arthrocare Corp. Securities Litigation, 1:08-cv-00574-SS (W.D. Tex. 2010))
  • Successfully briefed and argued motion to dismiss on behalf of auditor in securities class action. Issues included subject matter jurisdiction, personal jurisdiction, forum non conveniens, and the PSLRA. (Parks, et al. v. Fairfax Financial Holdings Ltd., et al., 2010 WL 1372537 (S.D.N.Y. 2010))
  • Represented defendants in successful motion to dismiss in derivative action alleging breaches of fiduciary duty under Maryland law.  (Nadoff v. Walton, et al., 2007 CA 00160 B (D.C. Super. 2007))
  • Defeated class certification on behalf of clients in a federal securities class action. (In re Red Hat, Inc. Securities Litigation, No. 5:04-CV-473-BR (E.D.N.C. 2007))
  • Represented defendant accounting firm in a winning motion to dismiss a shareholder derivative complaint. (In re Bristol-Myers Squibb Derivative Litigation, 2007 WL 959081 (S.D.N.Y. 2007))
  • Represented various amici in District Court briefing concerning government's violation of defendants' rights to fully defend themselves in the KPMG tax shelter fraud case. (U.S. v. Stein, 452 F. Supp. 2d 276 (S.D.N.Y. 2006))
  • Filed amicus brief with Second Circuit arguing that, in criminal prosecution of alleged accounting fraud, government must introduce relevant accounting standard and expert testimony. (U.S. v. Rigas, 05-3577-cr(L) , 05-3589-cr (CON) (2006)) 
  • Successfully defended auditor appointed pursuant to Master Settlement Agreement (MSA) in state court litigation arising from tobacco company's allegations that it had been subject to excessive levies pursuant to the MSA. (Top Tobacco v. Kentucky, et al., 05-CI-1172 (Ky. Cir. 2005); Top Tobacco v. Virginia, et al., 05-1313-4 (Va. Cir. 2005))
  • Represented the defendants in a successful motion to dismiss a securities class action complaint alleging fraudulent accounting. (In re Allied Capital Sec. Litig., Fed. Sec. L. Rep. 92,411 (S.D.N.Y., Apr 25, 2003))
  • Represented one of the defendants in a case alleging securities fraud arising from violation of defendants' duty of best execution. The Third Circuit upheld the trial court's denial of class action status. (Newton v. Merrill Lynch, et al., 259 F.3d 154 (3d Cir. 2001))

Professional Activities

Mr. Davies has been a panelist and speaker at events concerning auditor liability, financial statement fraud, government enforcement priorities, internal investigations, privilege and the SEC's policy on corporate penalties. He also serves on the Stanford Law School Board of Visitors and is a member of the National Chamber Litigation Center's Securities Litigation Advisory Committee, which advises NCLC on when to become involved as an amicus in securities litigation.

Practices

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Education

JD, with Distinction, Stanford Law School, 1996, Senior Articles Editor, Stanford Law Review; Lead Editor, Stanford Journal of International Law; Editor, Stanford Law & Policy Review

BA, with High Honors, Wesleyan University, 1993, Phi Beta Kappa

Beijing Normal University, 1988-89

National Taiwan University, Inter-University Program for Chinese Studies, 1991-92

Bar Admissions

District of Columbia

New York

Languages

French

Chinese

Clerkships

The Hon. James L. Buckley, US Court of Appeals for the District of Columbia Circuit, 1997 - 1998

The Hon. William W Schwarzer, US District Court for the Northern District of California, 1996 - 1997

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