For more than 10 years with the Enforcement Division of the CFTC (2008 – Present), I have investigated suspected violations including fraudulent solicitations, misappropriation, suitability, churning, negligence, failures by Commission registrants to properly supervise their employees, market manipulations, disruptive trading practices and market abuses, false reports, potential fraud in pooled or managed accounts, Ponzi Schemes, position limit violations, and institutional issues.
My responsibilities involve analyzing information obtained during investigations, evaluating facts, taking investigative testimony, determining legal theories, writing memoranda, summarizing investigating results, researching and interpreting commodity laws and regulations, and recommending whether to commence enforcement actions.
I have been assigned to more than 160 investigations (certain of which have involved the FBI, DOJ, SEC, and other agencies) with 40+ resulting in Sue and Settle Agreements or litigation in Federal Court.
While in the litigation department at Citigroup Global Markets for over 15 years (1992-2008), I was an in-house litigation analyst and Expert Witness on behalf of Citigroup and its predecessor companies.
At Citigroup, I analyzed more than 1,000 securities arbitration matters and in excess of 200 futures matters and provided Expert Testimony in 52 securities cases and 24 futures cases before FINRA, NYSE, NASD, CFTC, NFA and in state court.
These litigation, compliance, and regulatory cases involved supervision, account performance, suitability, fraud, churning, unauthorized trading, turnover, asset allocation, margin, misrepresentation, breach of duty, negligence, and novel issues.
Prior to joining Citigroup in its litigation department, I held, between 1983 and 1992, futures operations and compliance positions of increasing responsibility with Merrill Lynch, Chase Manhattan Bank, First Boston Corporation, NFA, Deutsche Bank, and Swiss Bank.