CHRIS MILLS advises clients on a comprehensive range of enforcement and compliance issues relating to the federal securities laws. A partner in the Securities Enforcement and Regulatory practice, which was named the “Law Firm of the Year” for Securities Regulation or for Litigation – Regulatory Enforcement (SEC, Telecom, Energy) for 2023, 2021, 2020, 2017, and 2016 by U.S. News — Best Lawyers and received the 2019 Chambers USA Award for Financial Services Regulation, Chris regularly represents investment advisers, broker-dealers, investment banks, credit rating agencies, public companies, and current and former senior executives, traders, and employees in investigations involving the Securities and Exchange Commission, FINRA, the Department of Justice, the Commodity Futures Trading Commission, and other regulators.
In addition to representing clients in investigations and litigated enforcement actions, Chris has significant experience conducting sensitive internal investigations for financial services firms and public companies in response to whistleblower complaints or other allegations of misconduct. He also routinely counsels broker-dealers, investment advisers, and credit rating agencies on their obligations under the federal securities laws and conducts due diligence on regulated entities in connection with mergers, acquisitions, or other transactions.
Chris’s recent experience includes:
- Representing a major investment adviser in an SEC investigation of alleged breaches of fiduciary duty and conflicts of interest
- Representing a global asset management company in parallel SEC and federal grand jury investigations of allegedly manipulative trading and other conduct
- Representing a Fortune 50 public company in an SEC investigation of accounting and disclosure issues
- Representing a leading asset management firm in multiple SEC investigations regarding digital assets and DeFi services
- SEC v. Morningstar Credit Ratings – Representing credit rating agency in investigation and first-of-its-kind litigated enforcement action, resulting in partial dismissal of SEC’s claims and dismissal of SEC’s request for injunctive relief
- Representing a dual-registered broker-dealer and investment adviser in an SEC inquiry regarding off-channel communications
- In the Matter of Lek Securities Corp. – Representing The Options Clearing Corporation in an administrative proceeding brought by a participant challenging risk-management measures. Participant withdrew its petition for review following completion of briefing.
- Representing a prominent broker-dealer in an inquiry by FINRA and other SROs regarding compliance with the Market Access Rule
- Advising a major financial services firm in connection with an acquisition of a dual-registered broker-dealer and investment adviser
- Representing an NRSRO in an SEC investigation relating to credit ratings assigned to structured finance instruments
- Conducting an internal investigation on behalf of a registered investment adviser into alleged breaches of fiduciary duty and other misconduct
- Representing a significant hedge fund manager in an SEC investigation of potential insider trading
- Representing a large broker-dealer in a FINRA investigation of sales practices
- Representing a major investment adviser in an SEC investigation regarding compliance with Rule 105 of Regulation M
- Representing a former senior executive at a multinational bank in connection with an SEC and DOJ investigation of alleged money laundering and securities fraud
- Representing a multinational financial institution in CFTC and NYAG investigations regarding potential market manipulation
- Conducting an internal investigation on behalf of a leading broker-dealer concerning compliance with FINRA research rules
- Representing a senior executive at a major financial services firm in an RMBS-related FIRREA investigation by the DOJ
Prior to joining Sidley, Chris served as a law clerk to Judge Leslie H. Southwick of the U.S. Court of Appeals for the Fifth Circuit. Previously, Chris served on the staff of the United States Senate Judiciary Committee and, during law school, worked in the Division of Enforcement at the SEC.