Christopher Conte focuses on conducting independent and internal investigations and representing public companies, financial services firms, hedge funds, asset managers, accountants, and individuals in enforcement investigations and proceedings by the US Securities and Exchange Commission (SEC), the Financial Industry Regulatory Authority (FINRA), the Public Company Accounting Oversight Board (PCAOB), state securities regulators, and federal criminal authorities.
His practice also includes representing clients in Foreign Corrupt Practices Act (FCPA) matters, and advising clients with respect to corporate governance and securities law compliance.
Chris returned to Steptoe after a distinguished 17-year career in the Division of Enforcement of the SEC where he conducted and oversaw significant enforcement matters across all of the Commission’s major program areas. He supervised and brought enforcement actions involving:
- financial fraud, improper accounting, and internal controls and disclosure violations by public companies and their officers, audit failures by accounting firms and their partners, violations of the auditor independence and registration rules, illicit payments under the FCPA, manipulative short selling and unlawful IPO allocation practices, and insider trading by corporate insiders, securities market professionals, and accountants;
- investment advisers and private equity funds, including unlawful market timing arrangements, improperly valuing assets in investment portfolios, conflicts of interest, failures to disclose information to mutual fund boards during the investment advisory contract renewal process, and failures to disclose the source of distributions paid to fund investors in closed-end funds;
- broker-dealers and registered representatives, including failure to supervise violations involving deceptive trading to circumvent market timing restrictions, the failure to establish, maintain, and enforce written policies and procedures to prevent the misuse of material non-public information, sales practice abuses, and email preservation and production failures; and
- violations of the SEC’s proxy rules, tender offer rules, rules requiring the reporting of securities holdings, securities registration rules, and offering frauds and market manipulations.
During his tenure at the SEC, Chris also coordinated numerous enforcement matters with other federal law enforcement agencies, including the US Department of Justice and US Attorney’s offices as well as with self-regulatory organizations such as FINRA and the PCAOB.
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