Investigations, Enforcement Actions

• Represented multiple financial institutions in investigations related to swap dealer business conduct standards resulting in favorable resolutions or declinations.
• Represented large financial institution in connection with alleged manipulation of large FX option, resulting in a public declination.
• Represented multiple broker-dealers and proprietary trading firms involving complex algorithmic trading systems in SEC, CFTC, DOJ, NYAG, and SRO investigations.
• Represented broker-dealers in SEC and/or DOJ investigations involving CMBS underwriting, municipal bond pricing, illiquid asset valuation, Reg NMS, and the net capital rule.
• Represented broker-dealers and other market participants in SRO investigations related to best execution, cost basis reporting, Reg SHO, block trade and EFP requirements, and disruptive trading issues.
• Represented individual in high-profile CFTC and SRO investigation related to alleged misuse of confidential information to trade event contracts on CFTC-registered platform.   

Litigation

• Represented large digital asset trading platform in contested SEC enforcement action involving alleged sale of unregistered securities and purported wash trading, resulting in a voluntary dismissal with prejudice.
• Obtained summary judgment on behalf of a proprietary trading firm in putative class alleging spoofing and market manipulation under the Commodity Exchange Act, which was subsequently upheld on appeal. 

Regulatory Counseling

• Conducted strategic risk assessments for broker-dealers, national securities exchanges, designated contract markets, digital asset trading platforms, and proprietary trading firms regarding potential regulatory and operational risks.
• Regularly advises on propriety of proposed trading strategies and activities involving securities, commodities, digital assets, and event contracts.
• Regularly advises on digital asset and event contract activities, including registration requirements, production design, and market conduct standards.
• Regularly advise on various broker-dealer, swap dealer regulatory compliance issues, including recordkeeping, trade reporting, and business conduct standards.
• Regularly advises clients on collateral consequences and associated reporting obligations.