SEC, FDIC & OCC Enforcement, Compliance & Defense

A Wells notice, an MRA, a consent order, and a grand jury subpoena can all arise from the same set of facts. Defending one without accounting for the others is how a regulatory problem becomes a criminal one.

We defend individuals and institutions in investigations and enforcement proceedings brought by the Securities and Exchange Commission, the Federal Deposit Insurance Corporation, the Office of the Comptroller of the Currency, and the other federal financial regulators — including the Federal Reserve, FINRA, and state banking and securities authorities.

On the securities side, our work spans the full enforcement lifecycle: responding to informal inquiries and formal orders of investigation, negotiating document and testimony scope, defending witnesses in on-the-record testimony, submitting Wells responses, negotiating remedies and penalties, and litigating in administrative proceedings and federal district court. Matters include disclosure and accounting fraud, insider trading, market manipulation, investment adviser and broker-dealer conduct, custody and marketing rule issues, whistleblower-driven investigations, and books-and-records and internal controls charges.

On the banking side, we represent institutions and individual bankers in examination disputes, Matters Requiring Attention, formal agreements, consent orders, civil money penalty proceedings, and prohibition actions under 12 U.S.C. § 1818. We handle Bank Secrecy Act and anti-money-laundering examinations and enforcement, fair lending and UDAP referrals, capital and liquidity directives, safety-and-soundness findings, change-in-control and application matters, and the personal liability exposure that senior officers and directors face when an institution deteriorates.

Compliance is the cheaper half of this practice. We build and test compliance programs, run gap assessments against current examination expectations, conduct privileged internal reviews of suspected misconduct, advise on self-reporting decisions, and design remediation that regulators will actually credit. Where a client's conduct implicates criminal statutes, we manage the securities or banking matter and the Department of Justice exposure together.

What we handle

• SEC investigations, Wells submissions, and enforcement litigation
• FDIC and OCC examination disputes and enforcement defense
• Section 1818 consent orders, CMPs, and prohibition actions
• Bank Secrecy Act and AML examination and enforcement matters
• Individual defense for officers, directors, and registered persons
• Whistleblower and internal complaint investigations
• Compliance program design, testing, and remediation
• Self-reporting and cooperation credit strategy
• Parallel DOJ criminal exposure management
• Administrative proceedings and appeals to the courts of appeals

Who we represent

• Banks, thrifts, and holding companies
• Broker-dealers, investment advisers, and funds
• Public company officers, directors, and accounting personnel
• Bank directors and senior executives facing individual liability
• Fintech, payments, and digital asset businesses
• Compliance officers and internal audit personnel