Our team possesses decades-long experience responding to investigations, monitoring and resolving issues raised by regulators, state attorneys general and district attorneys– often before an investigation is publicly disclosed. We advise financial services companies, trading firms, and their executives and traders in connection with investigative and enforcement matters initiated by the SEC, CFTC, FINRA, FERC, MSRB, NFA, Public Company Accounting Oversight Board, securities and commodity exchanges, and other regulatory bodies. Leveraging the strength of our white-collar practice, we also represent clients in investigations by other federal and state regulatory agencies, the Department of Justice, and state criminal authorities, many of which are parallel to the civil enforcement matters we handle. Our work also includes responding to and resolving single and multi-state attorney general investigations, often alongside proceedings by regulators such as the FTC, the OCC or the CFPB. Moreover, we routinely engage with local prosecutorial authorities and defend matters pursued by those offices.
Our experience includes representing clients in regulatory and criminal investigations involving allegations of market manipulation, price manipulation, solicitation fraud, spoofing, wash sales, and other types of market abuses, as well as alleged false statements, sales practices, large trader reporting, swap reporting, and futures position limit violations. Our team conducts comprehensive, efficient internal investigations in connection with enforcement work. We represent individuals and companies in the nation's highest-profile criminal prosecutions and investigations. We frequently represent financial institutions and operating companies and their officers and directors in connection with white-collar issues such as allegations of money laundering, lender liability for securities fraud, common-law fraud, Racketeer Influenced and Corrupt Organizations Act (RICO) claims, and Foreign Corrupt Practices Act (FCPA) violations. We also have an active practice defending cryptocurrency industry participants and crypto-asset issuers with respect to federal and state enforcement actions, and remediating prior token issuances and pre-sales.
Representative Matters
- Representation of global financial institution in CFTC investigation of disruptive trading.
- Representation of major digital asset platform in CFTC investigation.
- Representation of global futures brokerage firms in investigation by CFTC and Chicago Mercantile Exchange concerning meeting net capital requirements.
- Representation of insurance company in SEC investigation of trading practices.
- Represented proprietary trading firm in parallel investigations of alleged market manipulation.
- Representation of financial institutions in investigations of swap reporting.
- Representation of many different energy traders and entities in CFTC, Federal Energy Regulatory Commission (FERC), and Department of Justice investigations of power, natural gas, crude oil, propane, heating oil, and gasoline trading activity.
- Representation of an institution in CFTC investigations of precious metals trading involving retail commodities transactions.
- Representation of many different traders and entities in CFTC investigations of cash market and derivatives trading in financial products, agricultural commodities, metals, and currencies.
- Representation of foreign commercial end-users in CFTC investigations of alleged cash market reporting violations.
- Representation of foreign traders in CFTC investigations of trading on US exchanges.
- Representation of clients in many different investigations conducted by the CME Group, the Intercontinental Exchange, the New York Mercantile Exchange, the Chicago Board Options Exchange, the National Futures Association, and other self-regulatory organizations and in proceedings before their business conduct committees and hearing panels.
- Representation of a foreign financial institution in an investigation relating to compliance with CFTC swap regulations.
News & Publications
Press Releases
April 29, 2025
Investigations & Enforcement Blog
UK, France and Switzerland Announce New Task Force To Tackle International Corruption Alliance
March 31, 2025
Client Alerts
NYDFS Proposals Target Overdraft Fees
January 27, 2025
By: Stephen A. Aschettino, Tarrian L. Ellis, Andrew Owens, Benjamin M. Saul
Media Mentions
The National Law Journal Quotes Dan Mullen on Impact of Trump's Regulatory Agenda
November 18, 2024
Media Mentions
Law360 Quotes Zoe Osborne in Article on the Top Corporate Crimes to Watch for the Remainder of 2024
July 30, 2024
Events
Seminars & Events
Developing an OTC Derivatives Trading Desk
October 1, 2024
Speakers: Alexandra C. Scheibe, Ryan Hayden, Daniel A. Mullen
Seminars & Events
Global Trade and Enforcement Symposium in Hong Kong
June 1, 2023
Speakers: Renato Antonini, Yongqing Bao, Brigida Benitez, Brian G. Burke, Ali Burney, Henry Cao, John Caracappa, Boyd Cloern, Robyn C. Crowther, Brian J. Fleming, Coy Garrison, Zoey Hong, Stanley C. Kuo, Amy J. Lentz, Michelle L. Levin, Patrick F. Linehan, Jamie Lucia, Alexandra Melia, Cáitrín McKiernan, Eva Monard, Darryl Nirenberg, Gwendolyn Prothro Renigar, Angus Rodger, Guy Soussan, David M. Stetson, Grace Wang, Philip R. West, Charles Whiddington, Wendy Wysong, Lin Yang, Bo Yue, Wilson Zhao