Dispute Resolution Partner, Washington, D.C.
“I focus on investigations and compliance matters, advocating for clients, managing risk and, where required, ensuring the survival of their business. I draw on my experience as a former SEC enforcement supervisor and counsel to a former SEC chairman, and provide calm, pragmatic counselling to clients in the most challenging business situations.”
Education and qualifications
Doug defends individuals and entities in a range of cross-border proceedings involving the SEC and other federal, state and foreign agencies. He also counsels clients about compliance, sanctions, corporate governance and disclosure issues. Doug previously served as counsel to former SEC Chairman Arthur Levitt. Prior to that, Doug served as a staff attorney and then supervisor in the SEC's division of enforcement, evaluating and enforcing compliance with the federal securities laws. Doug has been selected as a leading attorney in Chambers USA: America’s Leading Lawyers for Business; named as one of Securities Docket’s “Enforcement 40,” a list of the 40 best and brightest individuals in the securities enforcement field; and recognized as a “recommended lawyer” for corporate investigations and white-collar criminal defense by Legal 500 US.
Doug has advised clients in many investigations. These include advising:
- corporate and individual clients in FCPA investigations of hiring practices in high risk jurisdictions
- a subject in US Special Counsel Robert Mueller’s investigation
- South African-based companies involving accounting, internal controls, and disclosure matters
- a large Latin American bank in connection with a cyber incident
- global financial services companies and their employees in multiple regulatory investigations of potential money laundering, insider trading, supervision, controls, and other issues involving international and domestic clients
- a global financial services firm in connection with regulatory inquiries regarding supervision of an employee who perpetrated a fraudulent investment scheme; no enforcement action taken
- a global oil and gas company in connection with parallel SEC and DOJ criminal investigations arising from an accident in the Gulf of Mexico
- a global financial services firm in an CFTC investigation of supervision of system for processing exchange and clearing fees
- a U.S. energy construction and engineering company in an SEC investigation of revenue recognition and internal controls
- a global financial services firm and employees in regulatory investigations connected with derivatives trading, internal controls and disclosure issues
- an individual in an SEC investigation into pension disclosures; no enforcement action taken
- a foreign derivatives exchange in an SEC investigation that resulted in a 21(a) report, rather than an enforcement action and civil penalty
- numerous investment advisory firms and individuals in SEC insider trading inquiries in which no enforcement actions were taken
Doug has been an active volunteer on behalf of the Children's National Medical Center, and has regularly participated in the Be Brave & Shave initiative, which provides support, raises awareness and assists a blood and marrow transplantation program.
Doug regularly speaks at conferences and to the press about SEC enforcement and related issues, and publishes articles about emerging regulatory issues:
Notable Press Coverage:
- Bloomberg Markets: Rules & Returns Show, Bloomberg TV, November 23, 2018
- US claims Russian groups helped funnel Iran oil to Syria”, Financial Times, November 20, 2018
- Bharara Group To Explore Changing Insider Trading Laws”, Law360, October 11, 2018
- What would happen to Tesla without Elon Musk at the helm?”, CNN Money, September 29, 2018
- SEC endorses investor view of Elon Musk’s indispensable role at Tesla”, Financial Times, October 2, 2018
- Elon Musk mocks SEC amid settlement deal”, CNN Money, October 4, 2018
- Tesla investors angered at Musk's $420 lowball deal”, The Telegraph, August 12, 2018
- Yahoo’s $35m fine sends a message”, Financial Times, July 12, 2018
- Supreme Court says SEC judges improperly appointed”, Financial Times, June 22, 2018
- OFAC's crypto blacklist could drive investors to riskier exchanges”, International Financial Law Review, April 6, 2018
- Insider-Trading Crackdown Bolstered as Martoma's Appeal Rejected”, Bloomberg, August 23, 2017
- The Wolves of Wall Street breathe easy”, The Times, August 12, 2017
Conferences and Seminars:
- Panelist, Recent Trends and Developments in Cybersecurity and U.S. and International Enforcement, Santiago, Chile, November 29, 2018
- Panelist, “SEC Enforcement in the ICO market: EtherDelta, Airfox and Paragon Coin”, Linklaters Webinar, November 28, 2018
- Panelist, “Global Commodities Gym: Sanctions and Commodities – Partners in Crime”, Linklaters Webinar, November 15, 2018
- Panel Moderator, “Insider Trading Trends and Developments”, Securities Enforcement Forum 2018, Washington, D.C., November 1, 2018
- Speaker, “A Review of SEC Enforcement in 2017 and What’s Ahead for 2018,” Securities Docket Annual Webcast, Washington, D.C., January 18, 2018
- Panelist, “Insider Trading Trends and Developments”, Securities Enforcement Forum 2018, Washington, D.C., October 26, 2017
- Speaker, “SEC Enforcement – Key developments in 2015,” Securities Docket Annual Webcast, Washington, D.C., January 15, 2016
- Speaker, “Broken Windows and Self Disclosure Decisions in the World Where Everything is Enforced”, ABA 10th Annual National Institute on Securities Fraud, 2015
- Panelist, “SEC Administrative Proceedings: Why Does the SEC Insist on Home-Court Advantage While Disadvantaging Defendants on Discovery?”, ABA Ninth Annual National Institute on Securities Fraud, 2014
- SEC Enforcement: 2016 in Review and Looking Ahead to 2017”, Harvard School Forum on Corporate Governance and Financial Regulation, March, 15, 2017
- Chapter 21: Litigating with the SEC”, SEC Compliance and Enforcement Answer Book. Practising Law Institute, 2017.
Education and qualifications
Doug holds a Juris Doctor, cum laude, from Pennsylvania State University, Dickinson School of Law, and a Bachelor of Science from Pennsylvania State University.
Doug is a member of the District of Columbia and Pennsylvania State Bars, United States.