Paul spent seven years in the SEC Enforcement Division, working in the specialized Market Abuse and Asset Management Units. At the Commission, Paul investigated and brought actions involving accounting and disclosures, auditor and attorney negligence, regulatory compliance, offering fraud, market manipulation and insider trading. He also gained perspective on national and regional enforcement policy, serving as Counsel to the Director of Enforcement in Washington, DC and assisting the Chicago Regional Director with management issues.

Before and after government service, Paul handled government and internal investigations, securities class actions and derivative actions. Through his work, he counseled nationally recognized public issuers, investment advisers, broker-dealers, audit firms and nonprofit organizations, as well as the officers and directors who manage those firms. He began his career clerking for the Honorable James H. Michael, Jr. in the Western District of Virginia.

While in law school, Paul served as editor-in-chief of the Vanderbilt Law Review and participated in the Law and Business Program. He is a Certified Fraud Examiner (CFE).

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• Represented an audit firm responding to an SEC investigation involving cryptocurrency issues
• Defended an investment adviser and principals in an SEC investigation of performance advertising, obtaining a settlement that avoided individual liability
• Represented an investment adviser in an SEC investigation of self-reported misappropriation and review of share class selection disclosures, resulting in no action against the adviser
• Represented an investment adviser in an SEC investigation of self-reported misappropriation and review of share class selection disclosures
• Counseled hedge fund and principals in response to an SEC examination deficiency letter, avoiding an enforcement referral
• Conducted an internal investigation into market regulation oversight issues for national options and future exchange
• Conducted an audit committee investigation into financial reporting and accounting concerns for industrial company
• Represented a senior executive of a major international bank in investigations conducted by the NYAG, the SEC and other regulators into the bank’s sale of auction rate securities*
• Assisted a Fortune 500 defense contractor with the response to an SEC investigation related to Sarbanes-Oxley compliance*
• Counseled a former board member of a global information technology company in connection with a pretexting scandal and related governmental investigations*
• Defended the former chairman and CEO of a large automotive supplier in an SEC enforcement investigation and related white-collar prosecution*
• Represented an issuer during an SEC inquiry into credit disclosures and related Nasdaq process*
• Facilitated the response of a private equity fund and portfolio company to SEC requests relating to potential insider trading.*
• Conducted a forensic review of a global company’s compliance with FCPA policies*
• Investigated a potential market manipulation of stock in connection with a PIPE offering*
• Facilitated a national audit firm’s responses to multiple SEC inquiries*
• Advised the special committee of an alternative fuel supplier through an internal investigation, SEC inquiry and Nasdaq process relating to stock option grant practices*
• Counseled a leading Fortune 500 computer manufacturer in the course of an SEC investigation into accounting and financial reporting matters*
• Represented a major fund administrator in an SEC enforcement matter and related inquiries involving the marketing and distribution of mutual fund shares*

Fraud and Other Commercial Litigation

• Represented the officers and directors of nationally recognized utility in derivative and class action litigation arising from large-scale wildfires
• Defended a private equity firm in connection with an antitrust class action alleging manipulation of the leveraged buyout market*
• Represented a senior bank executive in an auction rate securities class action litigation*
• Counseled a prominent financial institution in commercial litigation related to the collapse of a futures commodity merchant*
• Represented a national audit firm involved in securities litigation involving complex accounting fraud*

Representative SEC Actions

• Brought action against a Chicago-area alternative energy company, its former CEO and its CFO for accounting and disclosure violations that prevented investors from knowing that reduced business from two significant customers had caused substantial declines in the company’s long-term financial prospects*
• Worked alongside accountants and another investigative team to bring charges against a national audit firm and two of its partners for ignoring red flags and fraud risks while conducting deficient audits of two publicly traded companies that faced SEC enforcement actions for improper accounting and other violations*
• Conducted an investigation that resulted in fraud charges against several alleged perpetrators behind a $78 million international pump-and-dump scheme involving the stock of Jammin’ Java, a company that operated as Marley Coffee and used trademarks of late reggae artist Bob Marley to sell coffee products. Assisted with related litigation*
• Investigated matter resulting in charges against a Chicago-area company, its two co-founders, and its former COO for selling more than 9 billion shares of penny stocks through purported stock-based loans, block trades and other transactions without registering with the SEC as a broker-dealer*
• Worked with the Municipal Securities and Public Pensions Unit to bring charges against the State of Illinois for misleading municipal bond investors about the state’s approach to funding its pension obligations*
• Conducted an investigation that resulted in charges against a purported biofuel company in Chicago and a dozen individuals in a pump-and-dump scheme that generated $4.4 million in illicit profits. Participated in litigation against non-settling defendants and Rule 102(e) proceeding against attorney who was active in the penny stock market*

Pro Bono

• Conducted a pro bono internal investigation of misappropriation by an employee of a nonprofit agency
• Investigated a potential misuse of federal grant funds by nonprofit organization on a pro bono basis*

* Matters handled prior to joining McDermott.

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