Sadis & Goldberg Successfully Defends SEC Investigation Against Clients: No Charges Filed
A Sadis & Goldberg (“Sadis”) team led by Sam Lieberman successfully defended a multinational financial service provider and its employee against an SEC investigation into the allegedly improper allocation of personal expenses to a Private Equity Fund. After a multi-year investigation, the Sadis team obtained an SEC Termination letter ending the investigation without any charges against its clients. This represents a victory for the clients, by avoiding SEC charges, financial penalties, and reputational harm.
Sadis achieved this outcome by actively engaging and cooperating with SEC enforcement staff at an early stage, to quickly and thoroughly address difficult factual and legal issues. This included multiple voluntary discussions of key evidence; and an extensive voluntary proffer presentation to SEC enforcement attorneys, including leaders in the SEC Asset Management Unit. Through this approach, Sadis was able to address and rebut the SEC’s concerns in detail, including arguments made by other parties attempting to pin the blame on our clients to distract from their own fault.
This is one of many recent successful results Sadis has obtained defending SEC investigations – including four SEC termination letters with no charges in the last three years. The Sadis team involved on these matters has included Sam Lieberman, Jim Ancone, and Scott Ferrier. If you have any questions about an SEC or other government investigation, examination, or legal issue, please contact Sam Lieberman at slieberman@sadis.com or (212) 573-8164.