Partner, Washington, D.C.
“With nearly 30 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.”
Education and qualifications
With nearly 30 years of experience, Doug focuses on representing clients in a range of regulatory enforcement and compliance matters, including matters involving insider trading, securities registration, fraud, the FCPA, US economic sanctions, financial reporting, ESG, 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 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's recent experience includes advising:
- 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; 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 in digital asset industry: advising a range of digital asset market participants on US securities, AML and sanctions laws, including in connection with requests for no-action relief from SEC.
- Numerous individuals and investment advisory firms: defending in SEC insider trading inquiries in which no enforcement actions were taken.
- U.S. Special Counsel Robert Mueller’s investigation: defending a subject in connection to the investigation.
- Numerous international mining companies: advising on anti-corruption, accounting, internal controls and disclosure matters
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.
Further work highlights includes 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.
Notable Conferences, Seminars and Podcasts:
- “The Most Important Issues in Business Crime – Germany and France,” Linklaters Podcast, June 20, 2022
- “The Changing Cybersecurity Landscape: Managing Risks from Compliance Implications to Double Extortion,” Law.Com Webcast with Control Risks, June 15, 2022.
- “The Most Important Issues in Business crime – US and UK,” Linklaters Podcast, May 19, 2022
- “Climate disclosure in the US: a deeper dive into the SEC’s proposal”, Linklaters Webinar, April 7, 2022
- “Being anti-racist at work”, Linklaters Podcast, March 4, 2022
- “SEC Enforcement: A Look Back at 2021, and What to Expect in 2022”, Securities Docket Annual Webcast, January 14, 2022
- “SPACs, Climate and ESG, and Emerging Enforcement Priorities,” Securities Enforcement Forum, Washington, D.C., November 4, 2021
- "Greenwashing concerns on hyperdrive: how to protect yourself against the risks”, Linklaters Webinar, September 10, 2021
- “ESG collective actions,” Linklaters Webinar, June 29, 2021
- “Non-financial misconduct and whistleblowing”, Linklaters Podcast, June 15, 2021
- “Recent global developments and trends in anti-money laundering”, Linklaters Podcast, May 11, 2021
- “ESG in the US, EU and UK – towards greater convergence”, Linklaters Webinar, April 19, 2021
- “Business Crime Outlook Series – Trends in the global fight against money laundering”, Linklaters Webinar, April 20, 2021
- “Global Business Crime Outlook”, Linklaters Webinar, February 22, 2021
- “ESG Outlook for the UK and the U.S. in 2021”, Linklaters Webinar, February 3, 2021
Notable Press Coverage:
- “US SEC official warns SPAC dealmakers of the risks and complexities tied to blank-check mergers”, Business Insider, April 2021
- “Potential for Reversal of SEC Policy on Net-Zero Shareholder Proposals”, ESG Investor, April 2021
- “SEC questions banks over their work with Spacs”, Financial Times, March 2021
- “Proxy season action on climate change will be hard to avoid”, Pensions & Investments, March 2021
- “SEC eyes securities lending, short selling in exam priorities”, IFLR, March 2021
- “US watchdog seeks greenwashing whistleblowers”, Financial Times, March 2021
- “Elon Musk could face SEC probe over Tesla’s $1.5bn Bitcoin bet”, The Telegraph, February 2021
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.