Insider Trading 360 - Enforcement Trends, Sweeps, Key Cases and Prosecutions

Bill is experienced in representing financial services firms, public companies, and their officers, directors, and employees in U.S. Securities and Exchange Commission (SEC) enforcement investigations, FINRA investigations, as well as related criminal investigations, internal investigations, and securities litigation. Over the years, Bill has led dozens of high profile securities matters including those involving insider trading, broker-dealer and investment adviser rules and regulations, accounting issues, public company disclosure requirements, and municipal securities regulation.
Bill served for eight years on the staff of the Enforcement Division of the SEC serving as a staff attorney, branch chief and senior trial counsel. While at the SEC, Bill led investigations and litigation involving accounting and financial fraud, insider trading, municipal securities, broker-dealer and investment adviser violations and market manipulation.

Joseph Sansone is Chief of the SEC Market Abuse Unit, a specialized group that uses data analysis to investigate complex insider trading rings and other abusive trading schemes and misconduct. Mr. Sansone’s work at the SEC includes actions charging more than 40 defendants in a scheme to trade on nonpublic information hacked from newswire services as well as numerous insider trading cases against corporate insiders, investment bankers, hedge fund traders, and others. In addition, Mr. Sansone has supervised SEC enforcement actions against individuals and firms for manipulating the price of securities including thought brokerage account takeovers and layering and spoofing. He has also been actively involved in the SEC’s efforts to expose misconduct by operators of exchanges, dark pools, and other trading venues and to hold them accountable for such violations. Mr. Sansone joined the SEC after working as a litigator at a law firm in New York and serving as a law clerk to the Honorable Nathaniel R. Jones on the U.S. Court of Appeals for the Sixth Circuit. He received his law degree from Harvard Law School and his undergraduate degree from Harvard College.

Carmen Lawrence focuses on securities-related government investigations and litigation. As a partner in our Special Matters and Investigations practice and co-lead of our Securities Enforcement and Regulation practice, Carmen represents public and private companies in a range of securities-related regulatory and business matters.
Carmen represents parties in investigations and litigation conducted primarily by the Securities and Exchange Commission, the Commodity Futures Trading Commission and the U.S. Department of Justice, as well as self-regulatory organizations and state securities regulators. She conducts internal investigations, provides crisis management advice, and counsels companies and regulated entities (broker-dealers and investment advisers) on their obligations under the federal securities law.
Previously, Carmen was Regional Director for the SEC's Northeast Regional Office, the agency's largest region covering 14 U.S. states and the District of Columbia. In this role, she oversaw all enforcement and regulatory operations in the region, bringing some of the SEC's most significant cases. Prior to that, she was Senior Associate Regional Director, heading up the Northeast Regional Office's Enforcement Division after serving in senior and staff roles.
Carmen is a frequent speaker and lecturer in continuing legal education programs on federal securities matters. She has received consistent recognition from Chambers USA as a Leading Individual for Securities Regulation and for Litigation—White-Collar Crime & Government Investigations, as well as for Financial Services Litigation.
In 2016, Legal 500 ranked Carmen for Securities Litigation—Defense. She has also been recognized by Benchmark Litigation as a New York Litigation Star, and was named to Securities Docket's inaugural Enforcement 40 list of top SEC enforcement lawyers in 2013.

George S. Canellos is a partner in the New York office of Milbank and Global Head of the Litigation & Arbitration Group.
Mr. Canellos represents financial institutions, public companies, asset management firms, and individuals in government investigations and contested litigation in federal and state courts, and advises clients on corporate governance and compliance with the securities and banking laws. Mr. Canellos has received national recognition and many awards for his achievements in litigation and capital markets enforcement. Praised by Chambers USA as “a tremendously talented lawyer” and “very cogent thinker” who is able to “handle difficult situations in a very calming matter,” Mr. Canellos has more than two decades of experience prosecuting and defending white collar criminal cases and civil actions arising under the securities laws, having served twice in federal law enforcement — most recently in top positions at the US Securities and Exchange Commission and earlier in his career as a federal criminal prosecutor in the US Attorney’s Office for the Southern District of New York. In March 2014, Mr. Canellos rejoined Milbank, where he was a partner from 2003 to 2009.
In his four and a half years at the SEC, Mr. Canellos served most recently as co-director of the SEC’s Division of Enforcement and before that, as the Enforcement Division’s acting director and deputy director. In those positions, Mr. Canellos set SEC enforcement priorities and policies, and supervised the civil law enforcement efforts —including in investigations, prosecutions, and trials — of approximately 1,300 SEC personnel in 12 offices across the country. From July 2009 until May 2012, Mr. Canellos served as director of the SEC's New York Regional Office, overseeing approximately 400 professional staff of enforcement attorneys, accountants, investigators and compliance examiners responsible for enforcement investigations and actions, and compliance inspections of New York-based investment banks, investment advisers, broker-dealers, mutual funds and hedge funds.
While at the SEC, Mr. Canellos supervised many of the landmark enforcement cases in recent years, including the insider trading actions against Raj Rajaratnam, many individuals associated with Galleon Management LP, and hedge fund managers associated with S.A.C. Capital; the first-ever action against the operator of a “dark pool” trading platform; actions against participants in the structuring of collateralized debt obligations and the securitization of mortgage loans; and actions concerning and clarifying the responsibilities of participants in the investment advisory and mutual fund industries. In these and other cases, he worked closely with top leadership of the US Department of Justice, FINRA, CFTC, State Attorneys’ General, and the U.K. Financial Conduct Authority, and financial markets regulators in Europe and Asia.
Mr. Canellos began his career in the Litigation Department of Wachtell, Lipton, Rosen & Katz, working principally on takeover disputes and securities litigation. In 1994, he joined the US Attorney’s Office in the Southern District of New York, where he served in a number of positions and led the prosecution of many high-profile cases. As Chief of the Major Crimes Unit, he supervised assistant US attorneys investigating and prosecuting large-scale financial crimes, and as Senior Trial Counsel of the Securities and Commodities Fraud Task Force he headed numerous prosecutions of individuals and corporations for accounting fraud, investment advisory fraud, insider trading and other violations of the federal securities laws. Mr. Canellos also served as Deputy Chief Appellate Attorney, overseeing the briefing and argument of criminal appeals before the US Court of Appeals for the Second Circuit.
Following his nine years of service at the US Attorney’s Office, Mr. Canellos joined Milbank as a litigation partner. At Milbank, he has advised many of the nation’s leading broker-dealers, investment advisory firms, and mutual fund companies on compliance with the securities laws and the rules of self-regulatory organizations. He led the defense of clients in many of the recent headline investigations of the financial industry, including investigations of a wide variety of accounting practices; revenue-sharing and market-timing practices of mutual funds; soft-dollar and directed brokerage practices of investment advisors and broker-dealers; specialist trading on the New York Stock Exchange; revenue-sharing practices of insurance carriers and brokers; the promotion of tax shelters and strategies by securities and accounting firms, and trading and financial transactions implicating US sanctions laws. Mr. Canellos has handled many jury and non-jury trials, and briefed and argued dozens of appeals before the US Court of Appeals for the Second Circuit and other courts of appeals.

Steve defends enforcement matters involving the Securities and Exchange Commission and other financial regulators. He protects clients' interests during regulatory inquiries, including investigative testimony. He advocates with regulators in meetings and written submissions, including SEC Wells submissions, to obtain "closing letters" and otherwise negotiates to reach fair and appropriate consent decrees. Where enforcement action cannot be avoided entirely or resolved on consent, he fights for clients in federal court litigation, including jury trials and appeals, and in administrative proceedings.
Based on peer surveys, U.S. News-Best Lawyers in America named Steve the "Securities Regulation Lawyer of the Year for New York City" in 2017, and in 2021 and 2022 recognized his practice as the national "Securities Regulation Law Firm of the Year," ranking Steve individually for both securities litigation and securities regulation for well over a decade. Chambers USA has ranked him nationally since 2009 for "complex and sensitive SEC enforcement actions and investigations on behalf of public companies and broker dealers," with "significant strength in financial fraud and accounting issues." Chambers has reported peer comments that he is a "real leader of the SEC enforcement Bar" and that "you will find no one who knows more about how to litigate at the SEC."
Steve testified three times before Congress, most recently in 2019 at a House Committee on Financial Services hearing on SEC enforcement reforms and on cryptocurrency regulation and twice during the financial crisis. He has chaired both the Federal Bar Association's Securities Law Section, and the DC Bar's Corporation, Finance and Securities Law Section. He presents panels and writes on securities topics, including an academic article "Insider Trading: Where Is the Line?" in the Columbia Business Law Review that was favorably noted in The Economist, and most recently a 2022 article "Shadow Trading Becomes Insider Trading" in Columbia Law School's Blue Sky Blog. He has guest-taught law classes and symposia at Columbia, Georgetown, and other law schools on SEC enforcement topics.
During 14 years at the SEC, Steve co-managed its Enforcement Division's large Trial Unit in prosecuting jury and non-jury securities cases in federal courts and in SEC administrative proceedings around the country. First joining the SEC as a senior trial counsel at its Washington headquarters, Steve continued to personally litigate and try cases after promotion to Enforcement Division leadership and the Senior Executive Service. He earned the SEC-wide Productivity Improvement Award for his management skills. A Brooklyn native, he graduated from Columbia Law School and began his career at a large New York law firm before joining the SEC.
Since returning to private practice after his SEC service, Steve has achieved successful outcomes in securities enforcement matters for many entities and individuals. Currently, he is advocating for clients in investigations and litigation spanning the breadth of the SEC's enforcement program. He also presents professional panels and publishes articles exploring new developments in SEC policy and securities law and regulation.
Steve was a shareholder at McGonigle P.C., before the firm combined with Davis Wright Tremaine.