Alec Koch is a Partner in the Special Matters & Government Investigations practice group, resident in the Washington, D.C. office. From 2002 to 2016, he served as a Senior Counsel, Branch Chief, and Assistant Director in the Securities and Exchange Commission’s Division of Enforcement. During his time at the SEC, Mr. Koch supervised, conducted, and litigated investigations and enforcement actions relating to all areas of the SEC’s enforcement program, including matters involving broker-dealers, credit rating agencies, investment advisers, insider trading, public company accounting and disclosure, the Foreign Corrupt Practices Act, offering fraud, and microcap fraud. Koch has extensive experience working with the SEC’s other divisions and offices, as well as with FINRA, federal and state criminal authorities, and foreign securities regulators. Prior to his departure from the SEC, Koch was a member of the Enforcement Division’s Broker-Dealer Task Force Steering Committee, which is responsible for developing and overseeing investigative initiatives regarding broker-dealers. He also served as the co-chair of the Division of Enforcement’s Priorities and Resources Subcommittee. In that role, Koch helped to conduct a review to evaluate the Division’s priorities and allocation of resources, and made recommendations that led to the establishment of the Division’s Financial Reporting and Audit Task Force, Microcap Fraud Task Force, and Broker-Dealer Task Force. He also served as a member of the Enforcement Division’s Hiring Committee for the SEC’s main office in Washington.
Prior to his time at the SEC, Mr. Koch was an associate with King & Spalding.
Representative SEC Experience
- Supervised investigation that resulted in a settled action and $22 million penalty against a major broker-dealer for failing to have adequate policies and procedures to address the risk that material, nonpublic information about pending research changes would be improperly disseminated during weekly meetings between the firm’s research analysts and traders.
- Supervised investigations that resulted in the SEC’s first two enforcement actions against Nationally Recognized Statistical Rating Organizations and associated individuals.
- Supervised investigation that resulted in a settled action and $25 million penalty against a global resources company for failing to devise and maintain sufficient internal controls over its global hospitality program connected to the company’s sponsorship of the 2008 Summer Olympic Games.
- Supervised covert investigation that resulted in the filing of an emergency action to halt a multi-million dollar pyramid scheme targeting the Asian-American community and investors worldwide.
- Supervised investigation that resulted in settled charges against eight people for insider trading in the securities of a public company ahead of an announcement that it would be acquired. Negotiated cooperation agreement with a company executive who provided substantial assistance to the investigation.
- Supervised and conducted multiple investigations that resulted in antifraud, reporting, books and records, and internal controls charges against public companies and senior officers.
- Supervised investigations that resulted in enforcement actions against SEC-registered investment advisers and their principals for violations of the antifraud and other provisions.
- Investigated and brought settled actions against a major broker-dealer and an equity research analyst for antifraud and other violations arising from conflicts of interest between research and investment banking, as well as a settled administrative proceeding against two of the firm’s executives for related supervisory failures.
- Investigated and litigated an action against a broker who engaged in fraudulent trading and unsuitable sales of inverse floater CMOs to retail investors. After a two-week jury trial, the defendant was found liable on all counts, ordered to pay over $6 million in monetary remedies, and barred from the securities industry.
Awards & Recognition
- SEC’s Capital Markets Award (2004)