G. Jeffrey Boujoukos

Combining his government and private practice experience, Jeff advises clients in collaboration with Morgan Lewis’s corporate and business transactions, white collar defense, and investment management practices. Jeff also serves on the firm’s ESG & Sustainability Advisory Working Group and advises companies and financial services firms on matters related to ESG reporting and disclosure.

As regional director, Jeff supervised the SEC’s examination and enforcement programs in Pennsylvania, Delaware, Maryland, Virginia, West Virginia, and the District of Columbia. He led a staff of approximately 160 enforcement attorneys, accountants, investigators, and compliance examiners who investigated and enforced the federal securities laws and performed compliance inspections in the Philadelphia region with jurisdiction over nearly 1,200 investment advisers and investment companies with more than $10 trillion in assets under management. Further, he closely coordinated with state and federal criminal authorities on a number of parallel investigations.

Jeff also spearheaded the SEC’s outreach efforts to retail investors in the Philadelphia region, meeting with registrants, senior investors, college and high school students, and members of the military to promote financial literacy and help protect against fraud. In 2016, he was recognized by the SEC with the Arthur F. Matthews Award for his "sustained demonstrated creativity in applying federal securities laws for the benefit of investors."

Prior to being named regional director of the Philadelphia office, Jeff served as the office’s associate regional director from 2014 to 2016. In that role, he supervised the region’s enforcement efforts, including the investigation and litigation of matters involving insider trading, financial reporting and accounting fraud, investment advisors, broker-dealers, offering frauds, and Ponzi schemes. He began his tenure at the SEC in 2009 as regional trial counsel for the office, conducting jury trials and emergency hearings, as well as supervising the Trial Unit staff, in actions pending in federal court and administrative proceedings.

In his time as a partner at Morgan Lewis before joining the SEC, Jeff represented broker-dealers, clearing firms, investment advisers, mutual funds, and individuals regarding matters pending with the SEC in Washington, DC, and in its regional and district offices across the United States. Additionally, Jeff represented clients in connection with matters before SROs and state authorities such as the Attorney General offices of New York, New Jersey, and Ohio.

Jeff also has civil litigation experience in class action and other commercial matters. He has represented clients in shareholder and other class actions and complex litigation against corporations, directors, and officers. He has counseled clients in connection with failed transactions, closing balance sheet issues, and breaches of representations and warranties. These representations have taken him to federal and state trial courts throughout the United States.

Jeff has litigated to award a number of multimillion-dollar arbitrations before Financial Industry Regulatory Authority (FINRA) and American Arbitration Association arbitration panels, including matters involving claims against brokerage firms for breach of fiduciary duty, breach of contract, negligence, and breach of the federal securities laws.

Public Companies

• Represented Fortune 100 company in SEC reporting and disclosure investigation; matter closed with no enforcement action
• Represented audit committee board member in SEC reporting fraud investigation; matter closed with no enforcement action
• Represented public company in SEC investigation regarding cyber intrusion–related internal controls and disclosure; matter closed with no enforcement action
• Represented former public company officer in SEC insider trading investigation; matter closed with no enforcement action
• Represented public company in SEC Foreign Corrupt Practices Act (FCPA) investigation; matter closed with no enforcement action
• Represented public company in SEC revenue recognition, reporting, and disclosure investigation; matter closed with no enforcement action
• Represented public company in SEC investigation concerning internal controls and reporting
• Public company counseling and internal investigations on issues regarding insider trading, Regulation Fair Disclosure, governance, perquisites, internal controls, and reporting

Financial Services Firms

• Represented broker-dealer in first SEC enforcement action regarding Regulation Best Interest, filed in the US District Court for the Central District of California
• Represented president of a registered investment adviser in SEC investigation regarding false and misleading disclosures; matter closed with no enforcement action
• Represented broker-dealer in SEC investigation involving alleged failure to supervise and insufficient policies and procedures arising from outside business activities; matter closed with no enforcement action
• Represented, and continues to represent, investment advisers in SEC investigations involving mutual fund fee disclosure practices, including mutual fund and 529 plan share class selection, cash sweep revenue sharing, and marketing fees
• Represented market maker in a favorable resolution of an SEC investigation involving its anti-money laundering compliance program
• Represented broker-dealer in FINRA investigation involving option approval and surveillance practices; matter closed with no enforcement action
• Represented registered investment advisers in SEC investigations regarding alleged deficient disclosures in ADVs, prospectuses, and to mutual fund boards of directors
• Represented registered investment adviser in SEC review of cyber intrusion; matter closed with no regulatory action
• Represented registered investment adviser in SEC review of private fund cost allocations; matter closed with no regulatory action