Steven Peikin leads Sullivan & Cromwell’s Securities & Commodities Investigations Practice. Mr. Peikin brings decades of experience at the most senior levels of government and in private practice to his representation of clients in a wide range of regulatory enforcement investigations, white-collar criminal matters, and internal investigations. He has particular expertise in matters involving the federal securities and commodities laws.
Mr. Peikin is the only practicing lawyer to have held what are widely considered to be the country’s two most important government positions in securities enforcement: Director of the SEC’s Division of Enforcement (2017-2020), and Chief of the Securities Unit in the U.S. Attorney’s Office for the Southern District of New York (2003-2004). At the SEC, he supervised over 1400 people and had overall responsibility for all of the agency’s investigations and litigations across its 12 offices. At the U.S. Attorney’s Office, he oversaw 40 prosecutors, investigators, and staff responsible for some of the nation’s highest-profile financial statement fraud, insider trading, and obstruction of justice cases. As a prosecutor, Mr. Peikin also investigated and prosecuted a wide variety of securities, commodities, and other investment fraud schemes; and cases involving racketeering, murder, and other violent crimes.
Mr. Peikin has tried more than 20 criminal jury cases in federal court and argued numerous appeals before the U.S. Court of Appeals for the Second Circuit.
At Sullivan & Cromwell, Mr. Peikin has had a significant role representing institutions and/or their senior executives in virtually every major enforcement initiative of the past two decades, including those relating to the global financial crisis, benchmark interest rates, treasury auction manipulation, foreign bribery, insider trading, SPACs, and digital assets. Many of the world’s most sophisticated institutions have called on him to assist with their most important matters. His notable matters include:
- Coinbase, in investigations and litigation against the SEC, resulting in the SEC’s complete dismissal with prejudice of its entire case.
- Morgan Stanley in resolving a DOJ investigation of its block trading practices through a non-prosecution agreement on highly favorable terms, including a non-prosecution agreement.
- An international commodities trading firm in criminal and CFTC investigations of compliance with economic sanctions, resulting in a complete declination.
- One of the world’s largest alternative asset managers in a multi-year SEC investigation of its conflict of interest disclosures, resulting in a complete declination.
- One of the country’s largest banks in an SEC investigation of its cyber-security practices and disclosures, resulting in a complete declination.
- Goldman Sachs, in one of the world’s largest and most complex multi-country investigations arising from its dealings with Malaysian sovereign wealth fund 1MDB.
- Multiple individuals in various DOJ and SEC insider trading investigations, every one of which has resulted in declinations or dismissals.
- JP Morgan in resolving a DOJ investigation relating to its interactions with Bernard L. Madoff securities.
- Barclays Bank in resolving various multi-agency investigations relating to compliance with economic sanctions, LIBOR, and ISDAFIX.
- A crypto lending platform in resolving investigations by the SEC and more than 50 state and territorial securities regulators.
- A Silicon Valley “Unicorn” in resolving an SEC investigation of its historic accounting disclosures on highly favorable terms.
- In a criminal jury trial, the first defendant ever charged with “spoofing”
- Goldman Sachs, its board, and various members of senior management in criminal and SEC investigations and litigation arising from insider trading by its former director, Rajat Gupta.
