Doug Davison
Partner, Washington, D.C.
“With over 25 years of experience, 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.”
Overview
Professional experience
Education and qualifications
Published works
Overview
For more than 25 years, Doug has been representing individual and corporate clients in a range of regulatory enforcement matters involving allegations of fraud, FCPA violations, regulatory non-compliance and disclosure failures. Additionally, Doug has been deeply involved in helping clients identify and mitigate potential risks arising from US primary and secondary economic sanctions in connection with global transactions, including most recently related to Ukraine/Russia, Iran and Venezuela-related SDN designations. Additionally, Doug specializes in counselling clients through franchise threatening crises arising from regulatory matters. 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 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 sits on the Board of Advisors to the SEC Historical Society; is a member of the firm’s Global People Committee; sits on the Environment, Social & Governance Working Group; sits on the U.S. Diversity Committee; and sits on the Race Action Plan Steering Group.
He is a Race Champion, a mentor in Women’s Leadership Program and a mentee in the firm’s reverse mentoring program.
Work highlights
- Global accounting and professional services firm: defending in SEC securities fraud investigation.
- CFO of global food consumer products company: defending in SEC accounting and financial reporting investigation.
- Numerous corporate and individual clients: defending in SEC and DOJ FCPA investigations of hiring practices in high risk jurisdictions.
- 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 and employees: defending in SEC, DOJ and CFTC investigations connected with derivatives trading, internal controls and disclosure issues.
- Multinational technology company: advising on OFAC-related matters, including securing a business-critical operating license.
Professional experience
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 Board of Advisors to the SEC Historical Society; is a member of the firm’s Global People Committee; sits on the Environment, Social & Governance Working Group; sits on the U.S. Diversity Committee; and sits on the Race Action Plan Steering Group.
He is a Race Champion, a mentor in Women’s Leadership Program and a mentee in the firm’s reverse mentoring 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:
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“Under Trump, SEC Enforcement Of Insider Trading Dropped To Lowest Point In Decades”, NPR, August 2020
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“Ethics frameworks in the FS space”, Financier Worldwide Magazine, May 2020
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“Justice Department Investigating Lawmakers for Possible Insider Trading”, Wall Street Journal, March 31, 2020
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“Justice Department Looking Into Senator's Stock Sell-Off”, National Public Radio (NPR), March 31, 2020
- “U.S. Sanctions Compliance Fines Hit Decade High”, Wall Street Journal, July 25, 2019
- “This is what Europe's Iran trade conduit means”, Gulf News, July 15, 2019
- “SEC to ease burden on companies that violate securities laws”, Financial Times, July 3, 2019
- “Sanctions risk heightens as US tightens choke-hold on Iranian oil”, CDR, June 3, 2019
- “OFAC sanctions guidance is a “toolkit for compliance””, International Financial Law Review, May 28, 2019
- “New US sanctions on Iranian metals could stir dissent from within”, The National, May 9, 2019
- “Dernier tour de vis des Etats-Unis sur le pétrole iranien”, Les Échos, May 5, 2019
- “Countries importing Iran oil could face economic sanctions”, Gulf News, May 4, 2019
- “US Supreme Court backs SEC over misleading statements”, Financial Times, March 27, 2019
- “Elon Musk's SEC fight nears its moment of truth”, CNN Business, March 20, 2019
- “SEC Targets More Musk Tweets In Ongoing Contempt Push”, Law360, March 19, 2019
- “SEC faces unique challenge in face of Elon Musk's goading”, Financial Times, February 26, 2019
- “Apple Case Sends Warning To GCs On Insider Trading Risks”, Law360, February 14, 2019
- “U.S. Threatens Retaliation If Companies Tap Iran Trade Vehicle”, Bloomberg, February 8, 2019
- “3 European Nations Create Firm to Trade With Iran, but Will Anyone Use It?”, New York Times, January 31, 2019
- “European countries open Iran trade channel to bypass US sanctions”, Financial Times, January 31, 2019
- “EU Unveils Iran Trade Vehicle as It Vows to Salvage Nuclear Deal”, Bloomberg, January 31, 2019
- “Expect More SEC Cybersecurity Enforcement This Year”, Law360, January 17, 2019
- “Cybersecurity incidents up by two thirds” Global Data Review, January 14, 2019
- “Lutte anti-corruption, l'autre menace qui plane sur les fusions”, Les Échos, January 4, 2018
- 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:
- Speaker, "SEC Enforcement - Current Developments and What's Ahead for 2020", Webcast, December 10, 2019
- Speaker, "Sanctions - Cross border review, trends and impact on business", 2019 Frankfurt Compliance Symposium, October 29, 2019
- Panelist, “Cybersecurity Disclosure and Enforcement: How Tough Will the SEC Get?” SEC Enforcement Forum, Washington DC, October 23, 2019
- Panelist, The Sleeping Giant Awakes: The SEC Pursues New Cybersecurity and Data Privacy Cases Against U.S. Listed Companies, Privacy and Security Forum, Washington, D.C., October 16, 2019
- Speaker, SEC Enforcement Developments, AICPA & CIMA SEC Conference, Accounting and Reporting Update for U.S. Listed Companies and Foreign Private Issuers, Hong Kong, September 24, 2019
- Panelist, Roundtable on U.S. Government’s Recent Guidance on Corporate Compliance Programs, London, September 24, 2019
- Panelist, “Sanctions – cross border review and impact on business”, Linklaters Webinar, June 4, 2019
- Speaker, “SEC Enforcement — Current Developments and What’s Ahead for 2019,” Securities Docket Annual Webcast, Washington, D.C., February 22, 2019
- 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
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.
Published works
- “Chinese companies face new US listing challenges”, Corporate Secretary; IR Magazine, August 2020
- “Corporate Compliance Programs Take Center Stage in 2019 with New Guidance From the DOJ and OFAC”, The Review of Securities & Commodities Regulation, September 25, 2019
- “Leading by example”, International Financial Law Review, February 26, 2019
- “Expect More SEC Cybersecurity Enforcement This Year”, Law360, January 17, 2019
- “Anti-Corruption 2019”, Chambers and Partners Practice Guides, USA edition, 2018
- “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