Investigations & Enforcement.
The case is decided before the first subpoena.
The work — Internal investigations and enforcement defense. We are usually retained in the window between the moment a company knows it has a problem and the moment the regulator makes that interest formal. That window is where the charging theory is shaped.
What we cover — Audit-committee and special-committee investigations under privilege. SEC enforcement on accounting, disclosure and trading matters, through the Wells process. DOJ Fraud Section grand jury exposure for entities and individuals. FCPA, OFAC sanctions and export control. CFIUS and national-security review. Coordinated defense where a UK, EU or Asian regulator is running in parallel.
How we work — A privileged review under a non-waiver protocol comes first, and it moves quickly. Officers and directors get separate counsel from the first sign of a parallel proceeding — advancement, joint defense and common-interest questions are decided well in the first ninety days or badly forever. Where voluntary disclosure serves the client, we make it on a factual record we assembled, not one the staff assembled for us.
Recent matter — The former chief executive of a NYSE-listed software company facing parallel SEC and DOJ inquiries into three years of revenue recognition. The Department of Justice closed its file. The SEC settled on reporting-control terms with no fraud finding, no admissions and no officer-and-director bar.
