Doug Davison

With more than 30 years of experience, Doug focuses on representing clients in a range of internal and regulatory investigations and compliance matters, including matters involving whistleblowers, cybersecurity, crypto, insider trading, fraud, economic sanctions, anti-money laundering (AML), anti-corruption and disclosures. 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.

Doug is skilled at innovative arguments and defense strategies. In 2024, Law360 reported on how the Linklaters team he co-led won rare dual dismissals of DOJ and SEC insider trading cases on behalf of the former CIO of Viataris, the global pharmaceutical company. 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 Elite,” a list of the top-tier securities enforcement defense counsel; and recognized as a “recommended lawyer” for corporate investigations and white-collar criminal defense by Legal 500 US. Clients note that he “is involved in cutting-edge issues,” “is a terrific lawyer with a very versatile skill set,” “offers strength in insider trading, financial fraud and FCPA matters, and is particularly adept at handling cross-border investigations” (Chambers USA Securities: Regulation: Enforcement).

Work highlights

Doug's recent experience includes advising:

• Numerous global companies, their executives and their boards: advising in investigating and addressing whistleblower complaints. 
• Numerous individual employees at global financial services firms: representing in regulatory inquiries involving use of personal mobile phones for work.
• CFO of global food consumer products company: defending in SEC accounting and financial reporting investigation; no enforcement action taken.
• CEO of broker-dealer: representing in SEC and FINRA investigations involving AML, insider trading and other compliance matters; no enforcement action taken.
• Numerous corporate and individual clients in FCPA inquiries: defending in SEC and DOJ FCPA investigations of hiring practices in high risk jurisdictions.
• Leading companies and individuals in digital asset industry: advising a range of digital asset market participants on US securities, AML and sanctions laws, including SEC and DOJ investigations.
• Numerous individuals and investment advisory firms: defending in SEC insider trading inquiries in which no enforcement actions were taken.
• Numerous international mining companies: advising on insider trading, anti-corruption, accounting, internal controls and disclosure matters.
• A major European bank: advice in investigating and voluntarily self-disclosing hundreds of millions of dollars in transactions in potential violation of U.S. sanctions, ultimately securing a "no action" letter from OFAC upon closure of its investigation. 

Previously, Doug was chair of the corporate counsel committee of the Washington D.C. Bar's corporation, finance and securities law Section. He has been an adjunct professor at the George Washington University School of Law, where he taught a course on securities regulation. He has also served as a mentor to students of the Pennsylvania State University, the Dickinson School of Law and the Smeal College of Business at the Pennsylvania State University. 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 sits on the SEC Historical Society's Board of Trustees.

Further work highlights include advising:

• Global financial services companies and their employees: advising on multiple regulatory investigations of potential money laundering, insider trading, supervision, controls and other issues involving international and domestic clients.
• Global financial services firm: defending on regulatory inquiries regarding supervision of an employee who perpetrated a fraudulent investment scheme; no enforcement action was taken.
• Global oil and gas company: defending on parallel SEC and DOJ criminal investigations arising from an accident in the Gulf of Mexico.
• Global financial services firm: defending in an CFTC investigation of supervision of a system for processing exchange and clearing fees.
• U.S. energy construction and engineering company: defending in an SEC investigation of revenue recognition and internal controls.
• Global financial services firm and employees: defending in SEC, DOJ and CFTC investigations in connection with derivatives trading, internal controls and disclosure issues.
• General Counsel of State Pension Agency SEC investigation: defending an individual in a SEC investigation into pension disclosures; no enforcement action was taken.
• Foreign derivatives exchange: defending in an SEC investigation that resulted in a 21(a) report, rather than an enforcement action and civil penalty.
• Multinational technology company: advising on OFAC-related matters, including securing a business-critical operating license. 

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.