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Insider Trading Law 2019


Speaker(s): Andrew Bauer, Antonia M. Apps, Benjamin Naftalis, Brian A. Jacobs, Cynthia B. Adams, David I. Miller, Eugene Ingoglia, Harris Fischman, Kan M. Nawaday, Manal Sultan, Matthew L. Schwartz, Rebecca Monck Ricigliano, Simona Suh
Recorded on: Oct. 30, 2019
PLI Program #: 247786

Andrew Bauer is a law partner in the White Collar Defense and Securities Enforcement and Litigation practice groups at Arnold & Porter.  His practice involves defending organizations and individuals facing criminal and civil allegations of fraud and other misconduct in the financial services, healthcare, and other industries.  Prior to joining the private sector, Mr. Bauer served as an Assistant United States Attorney with the Criminal Division of the United States Attorney's Office for the Southern District of New York.  There he was a member of the Securities and Commodities Fraud Task Force, where he focused primarily on securities fraud, insider trading, investment advisor fraud, market manipulation, money laundering, and Foreign Corrupt Practices Act (FCPA) violations.  Throughout his career, Mr. Bauer has worked closely with the multiple governmental agencies regulating much of today's commercial activity, including the SEC, CFTC, FTC, FINRA, and FDA.  Before becoming an attorney, Mr. Bauer worked as a trader and analyst in the convertible bond and risk arbitrage groups at a hedge fund, as well as a project leader for an Internet venture company.  Mr. Bauer studied at the University of Pennsylvania (the Wharton School) and the University of Michigan Law School.


Cynthia Bookhart Adams is Managing Director and Head of Litigation, Regulatory and Employment Legal at Jefferies LLC, a global investment banking firm.  She leads the team responsible for a wide array of litigation, enforcement, and employment matters, including internal investigations, regulatory and compliance advice, and firm-wide policy initiatives. 

Prior to Jefferies, Cynthia held senior in-house legal roles at Morgan Stanley and Citigroup Global Wealth Management.  She joined Citigroup from WilmerHale, where she represented financial institutions in regulatory investigations and other matters.  Prior to WilmerHale, she served as an enforcement attorney in the New York office of FINRA (then NASD Regulation).  Cynthia began her legal career at Sullivan & Cromwell, following a federal clerkship for the Hon. Emmet G. Sullivan in the U.S. District Court for the District of Columbia.  She earned her law degree with honors from Howard University School of Law, and her undergraduate degree from the College of William & Mary.

Cynthia serves on the Executive Committee of the Compliance and Legal Society for the Securities Industry and Financial Markets Association (SIFMA), the leading industry group for the financial services industry.  She is also a member of the American Bar Association and the National Bar Association.  She frequently speaks on panels regarding ethics for legal and compliance professionals, best practices for regulatory and internal investigations, and success strategies for diverse counsel.  

Cynthia currently serves on the Board of Directors of the Northside Center for Child Development, a non-profit providing expert behavioral, mental health, education and enrichment programs to economically disadvantaged children and families in Harlem and Brooklyn.  At Jefferies, she has served on the Steering Committee of jWIN, the firm’s women’s leadership initiative, and on the Steering Committee for J-NOBLE, the Jefferies Network of Black and Latino Employees.

 


Eugene Ingoglia is a partner in the investigations and litigation practice at Allen & Overy LLP. His practice focuses on criminal, civil and regulatory securities and anti-corruption matters. He has extensive experience in handling sophisticated securities and business crime matters and has achieved notable results for a wide variety of clients over the course of his career, including successfully persuading the SEC not to pursue insider trading charges against two different clients over the past year.  He has represented entities and individuals in actions and investigations by various U.S. Attorney's Offices, the SEC, the CFTC, FERC, and FINRA as well as other federal and state regulatory agencies, involving allegations of insider trading, securities fraud, accounting fraud, market manipulation, FCPA violations, money laundering and healthcare fraud.  In addition, Gene has represented numerous clients at trial against the SEC and the U.S. Attorney’s Office, including a hedge fund portfolio manager in the recently completed “political intelligence” insider trading criminal trial in the Southern District of New York.

Previously, Gene was an Assistant U.S. Attorney for the Southern District of New York and a member of the Securities and Commodities Fraud Unit, serving as the lead attorney in numerous federal jury trials and complex white collar investigations. In that position, he represented the government in the trial and conviction of former SAC Capital portfolio manager Mathew Martoma in the largest insider trading scheme ever charged; and conducted the investigation that led to the conviction of former bank executives and traders for deliberately overstating the value of certain real estate backed securities, one of the few successful criminal prosecutions arising out of the financial crisis.

Gene has tried more than a dozen federal criminal cases and briefed and argued numerous appeals before the U.S. Court of Appeals for the Second Circuit.


Matthew Schwartz is a Partner in Boies Schiller Flexner’s New York City office. His practice  focuses on government and internal investigations, white collar defense, regulatory compliance, and complex civil litigation. A “buttoned-up assassin in the courtroom” praised by his colleagues for his “laser-like focus and precision,” Mr. Schwartz has a reputation for “possessing the consistent ability to take knotty issues and distilling them to their essence” (Forbes, 2014). “Talented and extremely hardworking” (Legal 500, 2017), he has first-chaired numerous jury and non-jury trials and personally argued more than a dozen federal appeals.

From 2005 to 2015, Mr. Schwartz was a federal prosecutor in the Southern District of New York, “where he spent a decade leading blockbuster trials” (Crain’s, 2017). As a member of that office’s Securities and Commodities Fraud Task Force, Mr. Schwartz led a number of high-profile matters, including the investigations and deferred prosecution agreements with JPMorgan and Commerzbank AG on BSA/AML charges; the investigation and prosecutions related to the “London Whale”  trades; and all aspects of the government’s investigation of Bernard L. Madoff Investment Securities, including a six-month long jury trial and the forfeiture of more than $9 billion. He conducted numerous investigations in parallel with regulators such as the SEC, CFTC, OCC, Federal Reserve Board, FinCEN, OFAC, and PCAOB; state Attorneys General and other state regulators, such as  the New York State Department of Financial Services; and foreign regulators and law enforcement, such as the UK Financial Conduct Authority.

Mr. Schwartz has frequently been recognized for his work. He was named as one of Crain’s New York Business “40 Under Forty” (2017); Law 360 named him to its “Top Attorneys Under 40” list  in 2016. And Ethisphere in 2015 and 2016 named him to its list of “Attorneys Who Matter.” He is a three-time recipient of the Department of Justice’s John Marshall Award – the highest award given by the Department to lawyers – and was named in 2013 as Prosecutor of the Year by the Federal Law Enforcement Foundation.

Education:

  • Columbia Law School, J.D.
  • Columbia College, B.A.

Former Positions:

  • Assistant U.S. Attorney
  • Law Clerk to Hon. Thomas J. Meskill (2d Cir.) and Shira A. Scheindlin (S.D.N.Y.)
  • Special Master, In re IPO Securities Litigation


Rebecca Monck Ricigliano, a former federal prosecutor, is a partner in Crowell & Moring’s White Collar and Regulatory Enforcement Group and a member of its Steering Committee; she is also a member of the firm’s Financial Services and Investigations practices. Rebecca is an experienced trial and investigations lawyer, serving nearly a decade as an Assistant United States Attorney in the U.S. Attorney’s Office for the Southern District of New York (SDNY) and then as the First Assistant Attorney General of New Jersey.

Rebecca conducts internal investigations for foreign and domestic clients, including Fortune 500 companies in the financial services, technology, transportation, government contracting, and defense sectors. Rebecca also represents individuals and companies in a wide array of grand jury and regulatory investigations and related enforcement, including criminal trials. Rebecca’s practice focuses on matters involving the Department of Justice’s Criminal and Antitrust Divisions, United States Attorney’s Offices, Congress, the Securities and Exchange Commission, the Commodities Futures Trading Commission, the Financial Industry Regulatory Authority, the Office of Foreign Asset Control, state attorney general’s offices, and other federal and state regulators. In addition to those representations, Rebecca regularly counsels clients on remedial measures and on the development and updates of corporate compliance programs and other corporate policies. She also provides training for clients and their employees.

Rebecca is regarded as a leading white collar attorney by Chambers USA, acknowledging her “phenomenal skill set” and “experience and gravitas to be able to speak directly to the court.” She was recognized by Crain’s New York Business as a “Notable Woman in the Law” in 2020, and by Best Lawyers in America in 2021.

Prior to joining Crowell, Rebecca served nearly ten years as an Assistant United States Attorney in the SDNY where she tried numerous cases and briefed and argued appeals before the U.S. Court of Appeals for the Second Circuit. During her tenure, Rebecca was a member of the Securities and Commodities Fraud Task Force and held various supervisory positions including Chief of the Narcotics Unit and Senior Trial Counsel in the Public Corruption Unit. As First Assistant Attorney General of New Jersey, Rebecca supervised complex criminal investigations and prosecutions and affirmative Consumer Fraud and False Claims Act cases. Prior to her government service, Rebecca was an associate at one of New York’s leading white collar criminal defense law firms, where she was a member of the defense team that represented Martha Stewart at trial.


A partner in the Litigation Department, Harris is a widely respected trial lawyer and litigator, and has extensive public and private experience in white-collar and regulatory matters. Harris regularly counsels companies, boards of directors, and senior executives in proceedings before regulators and prosecutors.

EXPERIENCE

Harris has handled major criminal and regulatory matters and internal investigations involving all aspects of alleged corporate misconduct. Harris frequently represents public companies and their executives in investigations conducted by the SEC’s Division of Enforcement and other regulators. Harris also routinely represents corporate and individual clients in a variety of matters before federal, state and local prosecutors across the country.

A seasoned trial lawyer, Harris has tried cases on behalf of commercial clients before juries and arbitration panels, and also has substantial appellate experience. Harris has successfully conducted more than 20 criminal and civil trials and arbitrations.

Harris previously served as an Assistant U.S. Attorney in the U.S. Attorney's Office for the Southern District of New York, where he was Chief of the Violent and Organized Crime Unit and before that Deputy Chief of the Narcotics Unit. As a prosecutor, Harris supervised more than 30 criminal trials.

Harris is a frequent speaker on various issues related to trial practice, regulatory enforcement proceedings and criminal law. He recently taught a seminar on federal prosecution at NYU School of Law. Harris served as a law clerk at the Office of the Prosecutor of the International Criminal Tribunal for the Former Yugoslavia, where he worked on the prosecution of Slobodan Milosevic, the former president of Yugoslavia, for attempted genocide and other war crimes.

Harris is a member of the 2020 class of David Rockefeller Fellows sponsored by the Partnership for the City of New York.


An experienced trial lawyer, former federal prosecutor, and Chambers USA-ranked white collar litigator, David I. Miller is a shareholder at Greenberg Traurig and focuses his practice on white collar criminal defense, government and internal investigations, securities and commodities enforcement, related complex civil litigation, and cryptocurrency, cybersecurity, anti-money laundering, and national security matters. Previously, David served for five years as an Assistant U.S. Attorney in the Southern District of New York (S.D.N.Y.), over half that time as a member of the Securities and Commodities Fraud Task Force. He also served as a terrorism prosecutor with the Department of Justice in Washington, D.C., as a Special Assistant U.S. Attorney in the Eastern District of Virginia, as an Assistant General Counsel for the Central Intelligence Agency, and as a white collar, securities, and commercial litigation attorney in private practice. Before joining Greenberg Traurig, David was a partner at another global firm.

David represents a variety of clients – including banks, broker-dealers, hedge funds, private equity funds, investment companies and advisers, public and private companies, cryptocurrency businesses, senior officers, directors, and managers, and other individuals – facing risks of government investigation, criminal, civil and regulatory enforcement and prosecution, related civil litigation, and in matters requiring complex internal investigations. David regularly assists clients facing insider trading, market manipulation (including spoofing), accounting fraud, valuation fraud, and other securities/commodities and financial fraud issues; Foreign Corrupt Practices Act and Bank Secrecy Act/anti-money laundering compliance concerns; and issues implicating cryptocurrency, cybersecurity, forfeiture, and national security matters. To this end, David represents clients before federal and state courts, the Department of Justice, US Attorney's Offices, Securities and Exchange Commission, Commodity Futures Trading Commission, self-regulatory organizations, state attorneys general offices, and other regulators and enforcement authorities.

David is recognized by Chambers USA as a leading white collar lawyer in New York, where clients have described him as “a great advocate who provides sound advice to his clients and can tell them what they need to hear.” He has also been described as “an effective trial lawyer who is unique in his ability to see the big picture, as well as the political and business implications of the case for the client.” Notably, clients have stated that David “provides excellent service – he’s proactive, incredibly responsive and professional.”  Similarly, The Legal 500 US notes that David has been praised by industry insiders for his “sharp mind, strategic thinking and client-focused advice.” David has also been recognized as a New York Super Lawyer in the area of white collar criminal defense (2015-present), as a “key lawyer” in Greenberg Traurig’s white collar/corporate investigations and blockchain/fintech practices by The Legal 500, and as a “Future Leader" by Who’s Who Legal.

As an experienced trial and appellate litigator with more than two decades of white collar criminal and financial litigation experience (as both a federal prosecutor and defense lawyer), David represents clients at all stages of litigation through trial and appeal. David has conducted 10 jury and bench trials, several of which were multi-defendant trials, including securities and accounting fraud trials, with guilty verdicts secured for nearly all defendants on all counts. As an appellate advocate, David has briefed and argued several appeals before the U.S. Court of Appeals for the Second Circuit.

While he was an Assistant U.S. Attorney in S.D.N.Y.’s Securities and Commodities Fraud Task Force, David was responsible for investigating and prosecuting a wide range of high-profile securities and commodities fraud offenses, including insider trading, investment adviser fraud, offering fraud, accounting fraud, options backdating, market manipulation, reverse mergers, credit default swap schemes, hedge fund improprieties, and Ponzi schemes. David handled multiple insider trading matters and was part of a team of prosecutors leading the government’s investigation and prosecution of Operation Perfect Hedge, which resulted in the conviction of more than 80 individuals for insider trading offenses since 2009. As part of his duties, he worked closely with, and coordinated parallel civil enforcement proceedings with, the SEC, CFTC, FINRA, and other regulatory agencies. While David was an Assistant U.S. Attorney, he also prosecuted numerous other criminal offenses, including bank, mail, wire, health care, and tax fraud; credit card fraud and identity theft; money laundering; obstruction of justice and false statements; terrorism offenses; export control violations; and narcotics, firearms, and robbery offenses. Additionally, he has experience with asset forfeiture issues, having litigated several criminal and civil forfeiture proceedings.

David previously served as a terrorism prosecutor with the DOJ’s Counterterrorism Section in Washington, D.C., where he investigated and prosecuted several high-profile terrorism-related cases through trial. He also served as a Special Assistant U.S. Attorney in the Eastern District of Virginia, where he investigated and prosecuted white collar, firearms, narcotics, and gang-related offenses through trial.

David’s career includes his time as an Assistant General Counsel for the Central Intelligence Agency, where he litigated and prosecuted cases on the CIA’s behalf (including classified and state secrets matters); was the assigned CIA representative to the prosecution team in United States v. I. Lewis (“Scooter”) Libby (D.D.C.); regularly advised senior CIA officials; and represented the CIA at high-level, interagency meetings implicating sensitive national security issues.

Before joining government service in 2005, David spent six-and-a-half years as a securities, complex commercial, and bet-the-company litigator with two large law firms in New York.

David has been recognized for his public service with Department of Justice and Central Intelligence Agency awards, is regularly quoted in the news media, and often appears on television news programs providing expert opinion.

David is also a technical advisor for the popular Showtime drama series “Billions.”


Antonia M. Apps is a former federal prosecutor and nationally recognized trial attorney with experience in criminal and civil matters. She represents financial institutions, corporations, and executives in regulatory enforcement proceedings, white-collar criminal investigations, complex commercial litigation and internal investigations. Prior to joining Milbank, Ms. Apps served as an Assistant U. S. Attorney in the Southern District of New York, where she led many of the government’s highest-profile securities fraud insider trading cases, including the prosecution of S.A.C. Capital Advisors. She was also the lead prosecutor at trial and on appeal in the landmark case of United States v. Newman.  Ms. Apps prosecuted over 20 insider trading defendants and tried numerous securities fraud trials. Lawdragon has named Antonia in its list of 500 Leading Lawyers in America every year since 2014. She is highly ranked in the Chambers USA listing for White-Collar Crime & Government Investigations, where clients and colleagues described her as a “terrific trial lawyer” who “understands the difficulties of the world we live in” and gives “advice tailored to a practical approach.” In 2020, Antonia was named a 2020 Litigation Trailblazer by The National Law Journal, which recognizes lawyers who have made significant impact on legal practice, policy or technological advancements, and in 2019, she was listed in Crain’s New York Business’s “Notable Women in Law” in recognition of her distinguished career. Antonia has also been recognized in Euromoney’s Expert Guide for White Collar Crime, Legal 500, Benchmark Litigation, and Global Investigations Review. She is a frequent speaker at industry conferences and teaches a class at Harvard Law School on white collar criminal law and procedure. She is a graduate of Harvard Law School, Oxford University and Sydney Law School, and clerked for Judge Fred I. Parker on the Second Circuit.


Benjamin Naftalis is the Global Vice Chair of the White Collar Defense & Investigations Practice and a partner in the Litigation & Trial Department.

A former federal prosecutor, Mr. Naftalis represents companies, boards, and executives in government and internal investigations, regulatory enforcement matters, high-profile disputes, and other sensitive situations throughout the US and internationally. 

Mr. Naftalis is consistently recognized by Chambers USA and The Legal 500 US in the area of white collar defense and investigations. In 2016, he was named a Law360 white collar Rising Star and a Rising Star by the New York Law Journal. In 2012, he received the US Attorney General’s Award for Distinguished Service – DOJ’s second highest award.

Mr. Naftalis has broad experience before a wide range of US regulators, including the Department of Justice (DOJ), the Securities and Exchange Commission (SEC), and the Commodity Futures Trading Commission (CFTC). He advises clients navigate allegations of securities and corporate fraud, insider trading, market manipulation, sanctions, money laundering, accounting and healthcare fraud, and international bribery and corruption.

Mr. Naftalis maintains an extensive civil litigation practice, including business disputes in federal and state courts and securities litigation.

Mr. Naftalis also regularly counsels private equity firms and hedge funds in deal-related diligence, trading, litigation, and regulatory compliance.

From 2006 to 2014, Mr. Naftalis served as an Assistant United States Attorney in the Southern District of New York. As a member of the Securities and Commodities Fraud Task Force, he investigated and prosecuted a wide range of federal securities and commodities fraud offenses. As a member of the Terrorism and International Narcotics Unit, he led many of the government’s highest-profile extraterritorial matters involving terrorism and national security, and international money-laundering and narcotics trafficking.

Mr. Naftalis has tried eight federal jury trials and briefed and argued over ten appeals before the US Court of Appeals for the Second Circuit.

Prior to joining the US Attorney’s Office, Mr. Naftalis clerked for Judge Jed S. Rakoff of the US District Court for the Southern District of New York and Judge Dennis Jacobs of the US Court of Appeals for the Second Circuit. He began his career as a corporate development analyst at DoubleClick, later acquired by Google. He continues to counsel leading and emerging technology companies.

Mr. Naftalis is a member of the New York City Bar’s White Collar Committee, a former term member of the Council on Foreign Relations, and a member of Latham’s global steering committee of its Women Enriching Business (WEB) initiative.

 


Brian A. Jacobs, a partner at Morvillo Abramowitz Grand Iason & Anello PC, is a former federal prosecutor and an experienced trial and appellate lawyer who represents individuals and organizations in criminal, civil, and regulatory matters, internal investigations, and appeals. His cases have involved allegations of financial fraud, antitrust violations, accounting fraud, insider trading, bribery and corruption, computer hacking, and trade-secrets theft.

Brian previously served as an Assistant U.S. Attorney in the U.S. Attorney’s Office for the Southern District of New York, where he was Deputy Chief of Appeals. During his six and a half years at the U.S. Attorney’s Office, Brian led the investigations and prosecutions of a wide range of federal crimes, including bank, wire, mail, and securities fraud, public corruption, money laundering, obstruction of justice, embezzlement, and cybercrime. As a prosecutor, Brian successfully conducted numerous jury trials, including multiple high-profile public corruption matters and complex white-collar cases. In his time as a prosecutor and in private practice, he has argued more than a dozen appeals before the United States Court of Appeals for the Second Circuit, and as Deputy Chief of Appeals, he co-authored briefs and supervised oral arguments in more than 50 additional appellate cases.

In recent years, Brian has been named a white collar “Rising Star” by Law360, which recognizes “attorneys under 40 whose legal accomplishments transcend their age,” and a "Rising Star" by the New York Law Journal, which recognizes "attorneys 40 and under who have established a record of accomplishments and demonstrated that they are top contributors to the practice of law and their communities." The Law Journal acknowledged Brian for handling “an impressive roster of headline-producing cases and successful prosecutions of corruption and other criminal cases” as a federal prosecutor. The Legal 500 United States has recommended Brian in the area of securities litigation, calling him “a superstar.” Additionally, Benchmark Litigation: The Definitive Guide to America’s Leading Litigation Firms & Attorneys has repeatedly recognized Brian as a “Future Star” and named him to its “Under 40 Hot List” four times.

In 2019, Brian was honored with a Burton Award for Distinguished Legal Writing for his Review of Securities & Commodities Regulation article, “How Institutional Dynamics Have Shaped Insider Trading Law.” Brian is the co-author of “Insider Trading” and “Securities Fraud,” two chapters in the treatise White Collar Crime: Business and Regulatory Offenses. Brian is also a co-author of the chapter “Responding to Subpoenas and Other Regulatory Requests” in the book Defending Corporations and Individuals in Government Investigations. Brian has written articles for The Review of Securities and Commodities Regulation and Practical Law, and is a regular contributor to The Insider Blog on Forbes.com.

Prior to joining the U.S. Attorney’s Office, Brian was a Law Clerk to the Honorable Amalya L. Kearse of the U.S. Court of Appeals for the Second Circuit, and the Honorable Jed S. Rakoff of the United States District Court for the Southern District of New York. Brian received his J.D. from Columbia Law School in 2004, where he was an Articles Editor of the Columbia Law Review, was named a James Kent Scholar each year, and was awarded the Paul R. Hays prize for civil procedure and the Charles Bathgate Beck prize for property law. He received his B.A. from Yale College in 2001, cum laude, with distinction in the English major.


Kan M. Nawaday is a seasoned trial, investigations, and criminal defense lawyer. A former Southern District of New York federal prosecutor, Kan zealously defends clients facing federal and state criminal and civil enforcement actions. He draws on his experience of having led more than 100 investigations, involving corruption and financial fraud; campaign finance fraud; bank, tax, and healthcare fraud; and money laundering.

Kan has tried 15 federal jury trials, and briefed and argued many federal appeals. National television news outlets often call upon Kan as a legal commentator – he has appeared on CNN, MSNBC, Bloomberg TV, and Vice News. Kan has also been quoted in newsprint publications, such as the New York Times. At Venable, Kan has conducted sensitive internal investigations, and has defended and advised clients in cases involving the federal and state False Claims Act, criminal antitrust, the Foreign Corrupt Practices Act, campaign finance fraud, art fraud, wire fraud, healthcare fraud, and sexual assault and harassment.

Government Experience

  • Assistant United States Attorney, U.S. Attorney's Office for the Southern District of New York – Nine Years (2009-2018)

Representative Matters

  • Defended a nonprofit organization against allegations of mishandling of a sexual harassment investigation, resulting in an appellate defense verdict before the Second Circuit Court of Appeals
  • Defended a multi-billion-dollar company in parallel state and federal False Claims Act investigations
  • Represented a private equity fund and directors of the fund’s portfolio company in connection with a DOJ healthcare fraud investigation of the portfolio company
  • Represented high-net worth individuals in connection with DOJ art fraud investigations

Education

  • J.D., magna cum laude, Cornell Law School, 2003
    • Editor-in-Chief, Cornell Law Review
  • M.A., French Language, Middlebury College, 2000
  • B.A., Comparative Literature, Yale University, 1996


Manal Sultan is currently the Deputy Director for the Division of Enforcement and is in charge of the Division’s New York office. Ms. Sultan represented the Division in many enforcement actions, including virtual currency matters, which are filed in the United States District Court and focus on allegations of manipulation, fraud, and trade practice misconduct. She has also successfully negotiated and settled many actions including benchmark cases and spoofing cases. Prior to being appointed Deputy Director, she has served as a chief trial attorney with the Division of Enforcement at the CFTC in New York. She also served as the Squad Leader of the Manipulation and Disruptive Trading squad of the Division. Ms. Sultan is a graduate of Fordham Law School. In addition, she holds an MBA in finance and information technology.


Simona Suh is an Assistant Regional Director in the Enforcement Division of the SEC and a member of the Division’s nationwide Market Abuse Unit.  She has been a key contributor to many SEC enforcement actions, including multiple insider trading cases, as well as cases involving market manipulation, unregistered securities offerings, misleading statements in dark pool operations, and other types of misconduct.  Before joining the SEC in 2004, Ms. Suh was in private practice in New York City and clerked for the Honorable Richard J. Cardamone of United States Court of Appeals for the Second Circuit and for the Honorable Carol B. Amon of the United States District Court for the Eastern District of New York.  Ms. Suh received her J.D., magna cum laude, from the Fordham University School of Law in 2001, and later taught legal writing at that law school.  She received her B.B.A. in Public Accounting, summa cum laude, from Pace University in 1998.