An Expert Panel Assesses the SEC’s Annual Enforcement Report

Sarah Heaton Concannon is a nationally recognized first-chair trial and appellate lawyer who serves as Co-Chair of Quinn Emanuel’s SEC Enforcement Defense practice and is resident in the firm’s Washington, D.C. and New York, N.Y. offices.  Sarah has over two decades’ experience representing and advising public companies, private funds, hedge funds, investment advisers, boards, audit committees, senior executives, and other individuals in bet-the-company litigation and governmental investigations.  Sarah brings together a practical, results-driven, client-centric focus, outstanding academic credentials, and a unique depth of knowledge regarding how to best navigate governmental and regulatory processes to achieve results for clients.

Sarah recently held senior positions at the U.S. Securities and Exchange Commission (SEC).  As Senior Trial Counsel at the SEC, Sarah litigated and investigated a wide array of securities matters, including actions for fraud, market manipulation, breaches of fiduciary duty, insider trading, violations of the Foreign Corrupt Practices Act (FCPA), excessive mark-ups, and disclosure and books and records violations.  Sarah’s federal district court litigations included high-profile and ground-breaking matters of key significance to the Commission, hundreds of millions of dollars recovered on behalf of investors, and multiple parallel criminal actions with the U.S. Department of Justice and U.S. Attorneys’ Offices.  Sarah was undefeated in dispositive motions, at trial, and on appeal.

While at the SEC, Sarah provided strategic advice and counsel in crypto and digital asset matters and also worked closely with both the Office of General Counsel and the Co-Directors of Enforcement on crypto-policy and the application of the Howey Test to evolving technologies.  Sarah has extensive experience handling matters involving cross-border enforcement, blocking statutes, and the IOSCO Multilateral Memorandum of Understanding.  She was a key member of a cross-divisional SEC team focused on uncovering potential violations of U.S. securities laws by entities and individuals located in the People’s Republic of China (PRC), and a go-to resource for the SEC’s coordinated enforcement response to legal developments in the PRC. 

Sarah also served as a member of the executive staff of the SEC’s Division of Enforcement as Senior Counsel to the Directors.  In that capacity, she advised the Directors on enforcement matters and regularly liaised with the Chairman and Commissioners.  Sarah prepared Congressional correspondence and testimony and aided Congress in considering and drafting legislation, including related to insider trading, statutes of limitations, disgorgement, and restitution.  As a result of having served on the Division’s executive staff, Sarah is uniquely situated to help clients navigate the SEC’s Wells process and cooperation program.  In 2020, Sarah received the SEC’s Douglas Adams Award for significant contributions to improving the effectiveness of the National Examination Program through personal leadership, and, in 2019, she received the Division Directors Award for her efforts securing tens of millions of dollars in unlawful trading assets in SEC v. Longfin Corp., et al., 18 Civ. 2977-DLC (S.D.N.Y.). 

Michael Liftik is Co-Chair of Quinn Emanuel’s SEC Enforcement practice, and Co-Managing Partner of the Washington, D.C. office. His practice focuses on government and internal investigations, regulatory enforcement defense, securities litigation, cryptocurrencies, congressional investigations, crisis management, and cybersecurity. Michael has extensive experience as a securities litigator, having worked on matters stemming from major securities regulatory crises, including market timing and late trading, stock options backdating, and the 2007-2008 financial crisis.  Michael spent nearly a decade at the Securities and Exchange Commission where he developed a unique depth of knowledge working on enforcement and regulatory matters at all levels of the Commission.  Michael has appeared on CNBC, CNN, and Bloomberg TV and has frequently been quoted in the Wall Street Journal and the New York Times for his expertise on these topics.

Michael brings his deep understanding of the securities laws and investigative processes to his representation of public and private companies, senior executives, asset managers, and broker-dealers before the SEC, FINRA, CFTC, DOJ, Congress, and in related civil litigation.  Michael also advises hedge funds and private equity funds on compliance issues, including during SEC examinations.  Michael litigates in federal and state courts around the country in securities class actions, disputes involving the financial services industry, and matters requiring a sophisticated understanding of complex financial products.  Michael leads internal investigations in accounting and financial reporting matters, cybersecurity breaches, and highly sensitive employment issues, and regularly assists clients in crisis management and public affairs responses to mission critical matters.

Prior to joining the firm, Michael was the Deputy Chief of Staff of the SEC, where he served as a senior legal advisor to Chair Mary Jo White on all aspects of the SEC’s operations, including enforcement, regulatory policy, compliance exams, agency strategy and direction, as well as the day-to-day management of the agency. Michael also served as Chair White’s deputy to the Financial Stability Oversight Council and was responsible for working with senior staff from other financial regulatory agencies on identifying risks and emerging threats to the financial stability of the United States.    He was also responsible for assisting the Chair in developing the agency’s policies on cybersecurity disclosure and data protection for registered entities and public companies. He led the SEC’s initial efforts to analyze areas where emerging financial technologies intersect with securities regulation, and directed the organization of the SEC’s first Fintech Forum. 

Before serving as Deputy Chief of Staff, Michael was Chair White's Senior Advisor on Enforcement, counseling the Chair on enforcement cases and policy matters.  Prior to his service in the Chair’s office, Michael was Counsel to the Director of the Division of Enforcement.  He began his career at the SEC in San Francisco as an Enforcement Division staff attorney where he investigated and litigated a wide range of securities law violations, including FCPA, insider trading, financial and accounting fraud, and complex offering frauds.  He was a member the Asset Management Unit, which is an enforcement group focused on cases involving investment advisers, private funds, and investment companies.  From January to April 2017, Michael served as the Acting Chief of the Complex Financial Instruments Unit, where he oversaw 45 attorneys and industry experts in offices across the country that investigate potential misconduct related to complex financial products, such as structured notes, asset-backed securities, and derivatives, and practices involving sophisticated market issues, such as fixed income trading and illiquid asset valuations.