Christopher R. Conte

Partner

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Areas of Work

Securities Enforcement, White-Collar Defense, Independent & Internal Investigations, Blockchain & Cryptocurrency

Overview

Chris Conte focuses on conducting independent and internal investigations and representing public companies, public accounting firms, financial services firms, officers, directors, auditors, and other individuals in enforcement investigations and proceedings by the US Securities and Exchange Commission (SEC), the Public Company Accounting Oversight Board (PCAOB), the Financial Industry Regulatory Authority (FINRA), state securities regulators, and federal criminal authorities. His practice also includes representing clients in Foreign Corrupt Practices Act (FCPA) matters, and advising clients with respect to corporate governance and securities law compliance. In addition, Chris advises companies on securities law issues associated with data breaches and digital assets and also represents them in SEC enforcement investigations.

Prior to joining Steptoe, Chris worked in the Division of Enforcement of the SEC for 17 years, where he held the position of Associate Director and conducted and oversaw significant enforcement matters across all of the Commission's major program areas. He supervised and brought enforcement actions involving:

financial fraud, improper accounting, and internal controls and disclosure violations by public companies and their officers, audit failures by accounting firms and their partners, violations of the auditor independence and registration rules, illicit payments under the FCPA, manipulative short selling and unlawful IPO allocation practices, and insider trading by corporate insiders, securities market professionals, and accountants;
investment advisers and private equity funds, including unlawful market timing arrangements, improperly valuing assets in investment portfolios, conflicts of interest, failures to disclose information to mutual fund boards during the investment advisory contract renewal process, and failures to disclose the source of distributions paid to fund investors in closed-end funds;
broker-dealers and registered representatives, including failure to supervise violations involving deceptive trading to circumvent market timing restrictions, the failure to establish, maintain, and enforce written policies and procedures to prevent the misuse of material non-public information, sales practice abuses, and email preservation and production failures; and
violations of the SEC's proxy rules, tender offer rules, rules requiring the reporting of securities holdings, securities registration rules, and offering frauds and market manipulations.

During his tenure at the SEC, Chris also coordinated numerous enforcement matters with other federal law enforcement agencies, including the US Department of Justice and US Attorney’s offices, and with organizations such as FINRA and the PCAOB.

District of Columbia

J.D., Catholic University of America, Columbus School of Law, 1988
B.A., Brown University, 1983

Areas of Work

Representative Matters

Representations of Individuals Before the SEC, PCAOB, DOJ, US Attorney Offices, and FINRA

Representation of an auditor at a public accounting firm in a PCAOB investigation of the firm’s systems of quality control relating to independence.
Representation of an auditor at a public accounting firm in a PCAOB investigation of compliance with PCAOB rules and quality control standards relating to integrity and personnel management.
Representation of an auditor at a public accounting firm in a SEC investigation of compliance with auditing standards.
Representation of a public company CFO in DOJ and SEC investigations of financial accounting issues.
Representation of a public company CEO in company, US Attorney's office, and SEC investigations of financial accounting and disclosure issues.
Representation of a public company assistant controller in a SEC investigation of financial accounting issues.
Representation of a public company VP of External Reporting in a SEC investigation of financial accounting issues.
Representation of a public company in-house lawyer in an US Attorney's office investigation of company disclosures.
Representation of a shareholder of a public company in a SEC investigation of financial accounting and disclosure issues.
Representation of a founder of a public company in a SEC investigation of financial accounting and disclosure issues.
Representation of an attorney in a SEC investigation of public company disclosures.
Representation of former senior officers of a pension fund in a SEC and Department of Labor pension fund investigation.
Representation of a public company director in SEC and US Attorney's office insider trading investigations.
Representation of an attorney in a SEC insider trading investigation.
Representation of a former public company executive and his wife in a SEC insider trading investigation.
Representation of a physician in a SEC insider trading investigation.
Representation of the principal of a political intelligence firm in a SEC investigation of the firm’s practices.
Representation of a foreign executive/investor in a SEC and US Attorney's office insider trading investigation.
Representation of an investor and family in a SEC insider trading investigation.
Representation of an attorney in an independent investigation conducted by FINRA.
Assisted in the representation of a transaction manager in a SEC investigation of the sale of interests in a CDO instrument.
Assisted in the representation of a company executive in a US Attorney’s office investigation of securities fraud.

Representations of Entities Before the SEC, PCAOB, and US Attorney Offices

Representation of a public accounting firm in a SEC and PCAOB investigation regarding compliance with auditing standards.
Representation of a public company in a SEC financial accounting and disclosure investigation arising out of a de-SPAC transaction.
Representation of a large foreign issuer in a SEC investigation of a data breach disclosure.
Representation of a large multinational corporation in a SEC FCPA investigation.
Representation of a company in an US Attorney's office investigation into alleged contracting corruption.
Representation of a company in a SEC investigation of potentially unregistered broker dealers.
Representation of an investment adviser in responding to SEC examination findings.
Representation of a FinTech company in SEC litigation.
Representation of crypto companies in SEC investigations involving token offerings.
Representation of a healthcare technology company in a SEC investigation involving an initial coin offering.
Advised a public company on data breach disclosure considerations.
Advised a large foreign issuer in a SEC FCPA investigation.
Advised multinational corporations in SEC FCPA investigations.

Independent and Internal Investigations

Conducted an independent investigation for a public company into financial accounting and disclosure issues.
Conducted an independent investigation for a large public utility company into management and employee workplace conduct issues.
Conducted an independent investigation for the Special Committee of the Board of Managers of Pilot Travel Centers LLC into allegations of fraudulent rebate and discount conduct involving the sale of diesel fuel to customers.
Conducted an internal investigation for a management company with regard to activities of a registered investment advisor.
Conducted an internal investigation for a federal contractor in connection with costs charged to government contracts.
Conducted an internal investigation for a publicly traded government contractor relating to securities sales and reporting by company executives.
Assisted in internal investigations for large multinational corporations with respect to potential bribery and export controls concerns.

Speaking Engagements

"GBBC Legal and Regulatory Group Update," Global Blockchain Business Council, February 24, 2021
"Insider Trading: The SEC is Watching," PilotLegis Annual Member Conference, Washington, DC, November 11, 2019