Securities Enforcement & Investigations
Ray represents clients in investigations and proceedings initiated by the Securities and Exchange Commission ("SEC"), the Department of Justice ("DOJ"), the Financial Industry Regulatory Authority ("FINRA"), U.S. Attorneys’ offices, state attorneys general, and other domestic and foreign law enforcement and regulatory agencies.
Ray has represented a broad array of clients, including public and private companies, including banking institutions, financial services companies, hedge funds, broker-dealers, investment advisers, their boards of directors and audit committees and their officers and directors, in government investigations involving allegations of securities and accounting fraud, and insider trading. He has conducted internal investigations on behalf of such entities in several of those matters, and also advised them regarding compliance with the securities laws, including various provisions of the Sarbanes-Oxley and Dodd-Frank Acts.
Representative Matters
- Conducted a global internal investigation into accounting irregularities for a multinational company.
- Represented financial institutions and brokers-dealers in several FINRA inquiries.
- Represented an investment advisor in SEC and FINRA investigations.
- Represented a broker-dealer in several arbitrations before FINRA and successfully obtained injunctions in four separate federal courts blocking these arbitrations as beyond the authority of FINRA.
- Successfully represented an investment advisor and its broker dealer in an SEC investigation of the creation and marketing of TVIX Exchange Traded Notes (“ETNs”).
- Represented several major financial institutions and investment advisors in SEC investigations of synthetic derivative and retail structured products, including, among others, STRATs, exchange-traded notes, and Capped Buffered Enhanced Participation Notes.
- Represented companies and their executives in a number of major insider trading investigations, enforcement actions, and court proceedings that also involved related actions and proceedings in other jurisdictions, notably in France and Switzerland.
- Successfully represented the head of the convertible bond desk at Drexel in enforcement proceedings before the SEC and criminal inquiries by the U.S. Attorney for the Southern District of New York, as well as in complex civil actions initiated by the FDIC and several private parties.
- Successfully represented the entity that founded Global Crossing and its principal shareholder in various investigative matters.
- Successfully represented a fund regarding potential violations of SEC regulations and advised them with respect to certain related audits.
- Successfully represented the chief financial officer of one of the major investment banks in an SEC inquiry and in a related shareholders class action litigation.