Chris Conte focuses on conducting independent and internal investigations and representing public companies, financial services firms, hedge funds, asset managers, accountants, and individuals in enforcement investigations and proceedings by the US Securities and Exchange Commission (SEC), the Financial Industry Regulatory Authority (FINRA), the Public Company Accounting Oversight Board (PCAOB), 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.
Chris returned to Steptoe after a distinguished 17-year career in the Division of Enforcement of the SEC where he 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 as well as with self-regulatory 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
Representations of Individuals Before the SEC and US Attorney Offices
- Represent public company CEO in company, US Attorney’s office, and SEC investigations of financial accounting and disclosure issues.
- Represent public company assistant controller in SEC investigation of financial accounting issues.
- Represent shareholder of public company in SEC investigation of financial accounting and disclosure issues.
- Represent founder of public company in SEC investigation of financial accounting and disclosure issues.
- Represent attorney in SEC investigation of public company disclosures.
- Represent attorney in SEC insider trading investigation.
- Represent public company in-house lawyer in US Attorney’s office investigation of company disclosures.
- Represent former executive and his wife in SEC insider trading investigation.
- Represent former senior officers of pension fund in SEC/Department of Labor pension fund investigation.
- Represent physician in SEC insider trading investigation.
- Represent principal of political intelligence firm in SEC investigation of the firm’s practices.
- Represent foreign executive/investor in SEC and US Attorney’s office insider trading investigation.
- Represent investor and family in SEC insider trading investigation.
- Assist in representation of transaction manager in SEC investigation of the sale of interests in a CDO instrument.
- Assist in representation of company executive in US Attorney’s office investigation of securities fraud.
Representations of Entities Before the SEC and US Attorney Offices
- Represent healthcare technology company in SEC investigation involving an initial coin offering.
- Represent large multinational corporation in SEC FCPA investigation.
- Represent investment adviser in responding to SEC examination findings.
- Represent company in US Attorney's office investigation into alleged contracting corruption.
- Represent company in SEC investigation of potentially unregistered broker dealers.
- Advise large foreign issuer in SEC FCPA investigation.
- Advise multinational corporations in SEC FCPA investigations.
Independent and Internal Investigations
- Conduct independent investigation for large public utility company into management and employee workplace conduct issues.
- Conduct 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 customer.
- Conduct internal investigation for federal contractor in connection with costs charged to government contracts.
- Conduct internal investigation for publically traded government contractor relating to securities sales and reporting by company executives.
- Assist in internal investigations for large multinational corporations with respect to potential bribery and export controls concerns.
News & Publications
April 26, 2018
October 13, 2015
- Associate Director, US Securities and Exchange Commission (2006-2010)
- Assistant Director, US Securities and Exchange Commission (2000-2006)
- Deputy Assistant Director, US Securities and Exchange Commission (1999-2000)
- Branch Chief, US Securities and Exchange Commission (1997-1999)
- Staff Attorney, US Securities and Exchange Commission (1992-1997)