Kurt Wolfe advises clients in connection with internal investigations and regulatory enforcement actions. A member of the Government Investigations, Compliance & Enforcement Section of the firm's Business Litigation Department, Kurt represents public companies, financial institutions, asset management firms, and individuals in federal and state government investigations and enforcement actions.

Kurt has many years of experience representing clients 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 investigations by the SEC, PCAOB, FINRA, state attorneys general, the US Department of Justice, and foreign criminal and civil regulatory agencies.

He also has extensive experience leading internal investigations. He is known for designing and executing practical, risk-based internal investigations that position clients to remediate current issues, mitigate future issues, and cooperate, as necessary, in related government investigations.

In addition, Kurt frequently advises clients on a host of regulatory compliance issues, including broker-dealer, FCPA, insider trading, investment adviser, cybersecurity and incident response, and whistleblower concerns.

Kurt regulatory writes and speaks on regulatory enforcement and compliance topics, such as SEC enforcement priorities and tactics, anti-bribery compliance and enforcement, and whistleblower programs.

Representative Matters

• Represented a worldwide banking and financial services corporation in connection with a large-scale internal investigation and inquiries from U.S. and foreign regulators relating to the client’s Brazilian operations, with a focus on potential embezzlement and FCPA issues.
• Represented a multinational advertising and public relations company in connection with SEC and DOJ investigations into the agency’s Brazilian and Indian operations, with a focus on potential FCPA issues.
• 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 a Canadian multinational banking and financial services corporation in connection with a large-scale internal investigation and inquiries from the SEC, DOJ and foreign regulators relating to its alleged role in facilitating the Allen Stanford Ponzi scheme.
• Represented an online brokerage firm in connection with a FINRA investigation involving books and records, advertising, suitability, and supervision issues, with a particular focus on whether online portfolio builder tools (“robo-advisers”) make “recommendations” under applicable FINRA rules.
• Represented an independent broker-dealer in connection with an internal investigation and related SEC and FINRA inquiries regarding potentially fraudulent trading practices on the broker-dealer’s fixed income trading desk, with a focus on suitability issues.
• Represented a Virginia-based non-publicly traded REIT in connection with a joint SEC and FINRA investigation into the REIT’s compliance with applicable disclosure requirements and accounting standards, with a focus on valuation issues.
• 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 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.
• Advise several New York-registered financial services firms on cybersecurity compliance issues arising under the New York Department of Financial Services Cybersecurity Regulation.
• Regularly advise hedge funds and private equity funds on potential insider trading issues and periodically conduct discreet investigations relating to same.

Publications and Speaking Engagements

• Author, "Where Have The SEC Enforcement Actions Gone?," Law360 (September 2018)
• Author, “Digital Realty and the Narrowing of Whistleblower Protections,” The Review of Securities & Commodities Regulation (May 2018)
• Speaker, “(Almost) everything you need to know about U.S. litigation, but were afraid to ask,” Allen & Overy University of Litigation (April 2018)
• Author, “Whistleblower update: SEC & CFTC programs busy in 2018,” Allen & Overy Investigations Insight (April 2018)
• Speaker, “SEC Investigations and Enforcement Actions in 2018: Practical Tips and Strategies,” Knowledge Group Webinar, Panelist (March 2018)
• Author, “3 Securities Enforcement Developments You May Have Missed,” Law360 (Feb. 2018)
• Author, “The SEC Enforcement Landscape: What to Watch in 2018,” Allen & Overy Investigations Insight (Jan. 2018)
• Author, “A Closer Look: Use of Compelled Testimony in United States Criminal Proceedings,” Allen & Overy European White Collar Crime Report (Nov. 2017)
• Co-Author, Chapter on US Law, “The International Comparative Legal Guide: Cybersecurity 2018,” Global Legal Group (Oct. 2017)
• Author, “SEC Creates Cyber Enforcement Unit,” Allen & Overy Investigations Insight (Oct. 2017)
• Co-Author, “Securities Enforcement Developments in Canada and the U.S.,” White Paper for the ABA National Institute on US-Canadian Securities Litigation (Oct. 2017)
• Co-Author, “Kokesh is a game changer for the SEC’s FCPA Enforcement Program,” Allen & Overy Investigations Insight (June 2017)
• Author, “The Case For Voluntary SEC Administrative Proceedings,” Law360 (June 2017)
• Speaker, “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, Panelist (February 2017)
• Author, “DFS Proposes First-in-the-Nation Cybersecurity Regulation,” Allen & Overy Investigations Insight (Nov. 2016)
• Author, “The Real-World Impact of the Yates Memo,” Law Journal Newsletters’ Business Crimes Bulletin (Aug. 2016)
• Author, “Our View: (Unintended) Consequences of the Yates Memorandum,” Allen & Overy Investigations Insight (Oct. 2015)
• Co-Author, “Recent SEC Award will Entice Foreign Whistleblowers to come Forward,” A&O White Paper (Sept. 2014)
• Securities and Exchange Commission to credit for compliance with foreign regulations? A&O White Paper (July 2013) (Co-author with Bill White)
• Speaker, “Navigating the Intersection of the FCPA, AML and Extraterritorial US Laws,” Securities Docket Webinar, Panelist (June 2013)
• Co-Author, “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) (Co-author with Robert Plotkin, Vivian Robinson, and Adam Greaves)
• Speaker, “Whistleblowers, State Secrets, and National Security,” The Center for the Constitution at James Madison’s Montpelier, Panelist (April 2012)
• A New Era of Global Anti-Corruption Enforcement, New York Law Journal (Feb. 2012) (Co-author with Robert Plotkin, Vivian Robinson, and Jeremy Freeman)
• Speaker, “New Rules for Whistleblowers,” Chicago Bar Association, Financial and Investment Services Committee (November 2011)
• Speaker, “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, Panelist (October 2011)

Professional and Community Involvement

• La Cocina VA, Board Member, 2018-Present
• DC Bar Foundation, Go Formal for Justice Fundraiser, Host Committee, 2013-2015
• DC Bar Association, Young Litigators Committee, Board Member, 2012-2014