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Wolfe, Kurt

Kurt Wolfe

Of Counsel

kurtwolfe@quinnemanuel.com
Direct Tel: +1 202 538 8379
Washington, D.C.
Tel: +1 202 538 8000 Fax: +1 202 538 8100

Kurt Wolfe is Of Counsel in Quinn Emanuel’s SEC Enforcement Practice. His practice focuses on government and internal investigations, regulatory enforcement inquiries, and securities litigation. Kurt has a wealth of experience representing clients in complex, bet-the-company investigations and enforcement actions, including matters stemming from the Allen Stanford Ponzi scheme, Operação Lava Jato in Brazil, so-called “princeling” hiring practices, the Scott Rothstein Ponzi scheme, and the Adelphia accounting scandal. Kurt has a deep understanding of the securities regulatory and enforcement landscape, and has written or contributed to stories for Bloomberg, CBS News, Compliance Week, The Hill, The New York Times, NPR, Reuters, and Yahoo! Finance.

A trusted advisor, Kurt is known for delivering tailored, practical advice in securities regulatory and enforcement matters. Public and private companies call on Kurt in a wide range of investigations and enforcement proceedings, including matters involving securities fraud, accounting fraud, FCPA violations, insider trading, and disclosure issues. He has successfully defended clients in actions by the SEC, PCAOB, FINRA, state securities regulators, securities exchanges, self-regulatory organizations, the U.S. Department of Justice, state attorneys general, and foreign criminal and civil regulatory agencies.

Clients also turn to Kurt to lead internal investigations. He has extensive experience designing and executing practical, risk-based internal investigations and helps clients remediate current issues, mitigate future issues, and navigate related government investigations. Kurt also advises clients on regulatory compliance issues, including broker-dealer, FCPA, insider trading, investment advisor, cybersecurity and incident response, and whistleblower concerns.

Kurt often publishes and speaks on regulatory enforcement and compliance topics, such as SEC enforcement priorities and tactics, anti-bribery compliance and enforcement, and whistleblower programs. He co-hosts a biweekly podcast produced by PLI — the inSecurities Podcast — that explores securities regulatory and enforcement developments.

  • Represented the investment advisory and brokerage subsidiaries of a full-service financial services firm in connection with an SEC investigation and enforcement action relating to the firm’s recommendations of complex exchange-traded products, including leveraged and inverse exchange-traded funds.
  • Represented a proprietary trading firm and market maker in connection with an OCIE examination relating to the firm’s market making activity on a Single Dealer Platform and related compliance obligations under Reg SHO and Rule 15c3.
  • Represented the brokerage subsidiary of a full-service financial services firm in connection with a FINRA examination and related enforcement action relating to the firm’s recommendation of 529 plan share classes.
  • Represented an online brokerage firm in connection with a FINRA investigation involving books and records, advertising, suitability, and supervision issues, with a focus on whether online portfolio builder tools (“roboadvisers”) make recommendations under applicable FINRA rules.
  • Represented an online brokerage firm in connection with a FINRA examination relating to the firm’s mandatory submission of options positions to the Large Options Positions Report (“LOPR”) and related supervision issues.
  • Represented an independent broker-dealer in connection with an internal investigation and related SEC and FINRA inquiries regarding suitability issues and potential “parking schemes” and other fraudulent trading practices on the broker-dealer’s fixed income trading desk.
  • Represented a global alternative investment manager in connection with a FINRA examination that identified exceptions relating to the firm’s compliance with suitability rules.
  • Represented the head of the municipal bonds trading desk at a multinational financial services corporation in connection with a FINRA investigation into the desk’s proprietary trading in municipal bonds.
  • Represented a global banking and financial services company in connection with coordinated investigations by the DOJ, SEC, FINRA, the Federal Reserve Bank of New York, and certain foreign regulators relating to practices on the company’s bond trading desk, with a focus on potential antitrust issues.
  • Represented an investment management firm and its COO in connection with an SEC investigation into an alleged fraudulent scheme to defraud investors by hiding losses on investments in residential mortgage-backed securities.
  • Represented a multi-billion-dollar hedge fund in connection with an internal investigation regarding potential violations of firm policies that restrict trading alongside the firm and sharing proprietary trading strategies.
  • Regularly advised hedge funds and private equity funds on potential insider trading issues and periodically conduct discreet internal investigations relating to same.
  • Periodically advised a multi-billion-dollar hedge fund sponsor on political intelligence and research vendor selection issues and due diligence.
  • Represented a British banking and insurance holding company in connection with an internal investigation and CFTC inquiries regarding allegations that the company manipulated prices in a credit derivatives auction.
  • Represented a Canadian multinational banking and financial services corporation in connection with a largescale internal investigation and inquiries from the SEC, DOJ and foreign regulators relating to its alleged role in facilitating the Allen Stanford Ponzi scheme.
  • Represented a worldwide banking and financial services corporation in connection with a large-scale internal investigation and inquiries from the SEC, DOJ and foreign regulators relating to the client’s Brazilian operations, with a focus on potential embezzlement and FCPA issues.
  • Represented a British multinational advertising and public relations company in connection with SEC and DOJ investigations into the agency’s worldwide operations, with a focus on potential FCPA issues in Brazil and India. Lead associate supervising aspects of the investigation relating to the company’s relationship with Petrobras.
  • Represented several individuals in a $49 million DOJ civil forfeiture case against assets acquired using funds allegedly misappropriated from 1MDB.
  • Advised the NY branch of a Swedish financial group on cybersecurity compliance issues arising under the New York DFS Cybersecurity Regulation.
  • Advised a national network of independent broker-dealers on cybersecurity compliance and reporting issues under the New York DFS Cybersecurity Regulation.
  • Represented an accountant with the Indian affiliate of a “Big Four” accounting firm in connection with parallel PCAOB and SEC enforcement proceedings alleging reporting and professional conduct violations.
  • Represented a Canadian derivatives trader in connection with a CFTC investigation into alleged manipulation of a swap tied to a bond issuance.
  • Represented a predictive analytics and data solutions client in connection with investigations by a cohort of state attorneys general involving alleged False Claims Act violations.
  • Represented a plank and luxury vinyl tile flooring distributor in connection with the U.S. Trade Representative’s investigation of China under Section 301 of the Trade Act of 1974.
  • London School of Economics
    (L.L.M., with distinction, International Business Law, 2007)
  • University of Richmond School of Law
    (J.D., cum laude, 2006)
  • James Madison University
    (B.A., cum laude, with distinction, History and English, 2003)
  • The District of Columbia Bar
  • The State Bar of Virginia
  • Troutman Pepper Hamilton Sanders LLP:
    • Associate, 2018-2021
  • Allen & Overy LLP:
    • Associate, 2012-2018
  • McGuireWoods LLP:
    • Associate, 2008-2012

Publications

  • Reevaluating the SEC’s Corporate Penalties Framework, Bloomberg Law (April 2021)
  • Reimagining the Role of the Next SEC Chair, The Hill (Jan. 2021)
  • A Hashtag Leads to Marketing #Success, Above the Law (Dec. 2020)
  • SEC Enforcement Case Offers Important Lessons about Internal Controls and Stock Buybacks, Troutman Pepper Client Alert (Nov. 2020)
  • Companies Must Keep Pace with Whistleblower Reporting, PLI Chronicle (Nov. 2020)
  • INSIGHT: Valuation in Uncertain Times—SEC Rulemaking, Enforcement, Bloomberg Law (July 2020)
  • Liu Case Reveals Two Paths for SEC Disgorgement, Bloomberg Law (July 2020)
  • Robo-Advisors: Regulators May Be Closer Than You Think, ThinkAdvisor (April 2020)
  • SEC Proposes Expanding Permissible Performance Advertising Practices with Favorable Treatment for Private Fund Managers, The Hedge Fund Law Report (Dec. 2019)
  • Top Takeaways from The SEC's Banner Enforcement Year, Law360 (Nov. 2019)
  • The Foundation of a Regulation Best Interest Compliance Program, FA Magazine (Nov. 2019)
  • SEC Finally Proposes Modernized Investment Adviser Advertising Rule, NSCP Currents (Nov. 2019)
  • Firms Should Stay Course Amid New Broker Standard Suits, Law360 (Sept. 2019)
  • Patchwork of Broker Conduct Regs Complicates Compliance, Law360 (July 2019)
  • INSIGHT: #HereWeGoAgain—The SEC’s Use of Hashtags Raises New Policy Questions, Bloomberg Law (June 2019)
  • INSIGHT: #Gamechanger at SEC—Hashtags Increase Eyes on Enforcement, Bloomberg Law (May 2019)
  • Potential New FCPA Enforcement Targets Come into Focus, Law360 (Feb. 2019)
  • The International Comparative Legal Guide: Cybersecurity 2019, Chapter on US Law, Global Legal Group (Oct. 2018)
  • Where Have the SEC Enforcement Actions Gone?, Law360 (Sept. 2018)
  • Digital Realty and the Narrowing of Whistleblower Protections, The Review of Securities & Commodities Regulation
  • Whistleblower update: SEC & CFTC programs busy in 2018, A&O Investigations Insight (April 2018)
  • 3 Securities Enforcement Developments You May Have Missed, Law360 (Feb. 2018)
  • The SEC Enforcement Landscape: What to Watch in 2018, A&O Investigations Insight (Jan. 2018)
  • A Closer Look: Use of Compelled Testimony in United States Criminal Proceedings, A&O European White Collar Crime Report (Nov. 2017)
  • The International Comparative Legal Guide: Cybersecurity 2018, Chapter on US Law, Global Legal Group (Oct. 2017)
  • SEC Creates Cyber Enforcement Unit, A&O Investigations Insight (Oct. 2017)
  • Securities Enforcement Developments in Canada and the U.S., White Paper for the ABA National Institute on US-Canadian Securities Litigation (Oct. 2017)
  • Kokesh is a game changer for the SEC’s FCPA Enforcement Program, A&O Investigations Insight (June 2017)
  • The Case for Voluntary SEC Administrative Proceedings, Law360 (June 2017)
  • DFS Proposes First-in-the-Nation Cybersecurity Regulation, A&O Investigations Insight (Nov. 2016)
  • The Real-World Impact of the Yates Memo, Business Crimes Bulletin (Aug. 2016)
  • Recent SEC Award will Entice Foreign Whistleblowers to come Forward, A&O White Paper (Sept. 2014)
  • Securities and Exchange Commission to credit compliance with foreign regulations? A&O White Paper (July 2013)
  • SDNY Finds No Duty to Disclose Wells Notices, McGuireWoods Subject to Inquiry (Aug. 2012)
  • FSA: Banks Have “More Work to Do” on Anti-Bribery Compliance, The Banking Law Journal (June 2012)
  • A New Era of Global Anti-Corruption Enforcement, New York Law Journal (Feb. 2012)

Speaking Engagements

  • inSecurities Podcast, Practising Law Institute (bi-weekly), https://www.pli.edu/insecurities/podcast
  • Building a Culture of Compliance,” Regulatory Compliance WatchApril 13, 2021.
  • “Into the Woods: Plotting a Course for a Successful Investigation,” Association of Certified Fraud Examiners Corporate Alliance Webinar (March 2021)
  • “Corporate & Securities Law in the Time of Coronavirus,” Securities Litigation Panel, University of Richmond Law Review Virtual Symposium (March 2021)
  • “The Games at GameStop,” University of Richmond Law & Business Forum, Panelist (Feb. 2021)
  • “Banking and Financial Regulation,” Symposium: Financial and Corporate Regulation in the Biden
  • Administration, Business Scholarship Podcast (Jan. 2021)
  • “2021 Regulatory Predictions,” IEX’s Boxes + Lines Podcast (Dec. 2020)
  • “New Developments in the SEC Whistleblower Program,” D.C. Bar Webinar (Dec. 2020)
  • “Trading and Markets – The Regulation of U.S. Stock Exchanges,” PLI Studio Briefing (Oct. 2020)
  • “Reg BI – Getting Caught Up, Getting Ready, Getting Ahead,” Regulatory Compliance Watch (April 2020)
  • “Reg BI: What every adviser needs to know (but is afraid to ask),” Investment News Webcasts (Dec. 2019)
  • “Financial Firm Spotlight: Enforcement and Regulatory Developments for Asset Managers, Broker-Dealers, Hedge Funds and More,” Securities Enforcement Forum 2019 (Oct. 2019)
  • “(Almost) everything you need to know about U.S. litigation, but were afraid to ask,” Allen & Overy University of Litigation (April 2018)
  • “SEC Investigations and Enforcement Actions in 2018: Practical Tips and Strategies,” Knowledge Group Webinar (March 2018)
  • “How to Effectively Deal with SEC Investigations and Enforcement Actions in 2017: (Potential) Changes to the SEC Enforcement Landscape in the Trump Administration,” Knowledge Group Webinar (Feb. 2017)
  • “US Regulatory Enforcement Hot Topics,” A&O Panel Discussions in London & Frankfurt (Dec. 2015)
  • “Navigating the Intersection of the FCPA, AML and Extraterritorial US Laws,” Securities Docket Webinar (June 2013)
  • “Whistleblowers, State Secrets, and National Security,” The Center for the Constitution at James Madison’s Montpelier (April 2012)
  • “New Rules for Whistleblowers,” Chicago Bar Association, Financial and Investment Services Committee (Nov. 2011)
  • “Whistle While You Work: Ethical Issues Associated with the Dodd-Frank Act’s Whistleblower Provisions and other Whistleblower Regimes,” The Dan K. Moore Program in Ethics, University of North Carolina School of Law (Oct. 2011)
  • Henrico County Democratic Committee, Vice-Chair for Communications