AARON JOHANSEN is a member of the firm’s Securities Enforcement and Regulatory group, which received the 2019 Chambers USA Award for Financial Services Regulation, and was named the “Law Firm of the Year” for Securities Regulation in 2020 and 2017 by U.S. News – Best Lawyers. Aaron focuses his practice on representing a wide variety of clients in investigations and enforcement actions by the U.S. Securities and Exchange Commission (SEC), the U.S. Department of Justice (DOJ), the Financial Regulatory Authority (FINRA), the Public Company Accounting Oversight Board (PCAOB) and other regulators. Aaron has handled matters involving, among other things, alleged security fraud, accounting fraud, insider trading, investment adviser and broker-dealer misconduct, disclosure irregularities, auditor independence, export controls and Foreign Corrupt Practices Act (FCPA) violations. Aaron also has represented clients in civil litigation in federal and state court and has experience in every aspect of pre-trial and post-trial activity, including discovery, motion practice, settlement negotiations and appeals.
In addition to his work on regulatory enforcement matters and litigation, Aaron has significant experience conducting internal investigations involving allegations of criminal, civil and ethical misconduct throughout the United States, as well as in Europe, Asia, South America and Africa. He also has experience counseling clients on a wide range of FCPA and anticorruption compliance issues and has helped design and implement global compliance programs.
Aaron’s representative matters have included:
- Representation of a broker-dealer in a FINRA investigation regarding research and trade-related issues.
- Representation of a Big Four accounting firm in an investigation regarding auditor independence.
- Representation of a broker-dealer in an SEC investigation regarding insider trading and market manipulation.
- Representation of a hedge fund in an SEC investigation of alleged violations of the Investment Advisers Act of 1940 and disclosure rules.
- Representation of a major investment bank, as well as certain current and former employees, in RMBS-related investigations by the SEC, state attorneys general and the DOJ, Civil Division.
- Representation of a China Big Four accounting firm in three-week hearing before SEC ALJ regarding China accounting firms’ inability to produce working papers directly to the SEC.
- Representation of a Fortune 100 company in internal investigations into potential FCPA violations in various jurisdictions.
Aaron has a commitment to public service and has represented a wide range of pro bono clients in matters including criminal appeals, sentencing hearings and custody disputes.
Aaron is proficient in Portuguese.