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Trading Investigations + Enforcement

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Edward Imperatore is a former Assistant United States Attorney for the Southern District of New York. He represents companies, financial institutions, boards, and executives in internal and government investigations and parallel regulatory and civil litigation. He is experienced in all aspects of white-collar crime and allegations of financial malfeasance, including securities and commodities fraud, accounting fraud, insider trading, market manipulation, BSA/AML violations, sanctions evasion, corporate fraud, digital currency crime, and violations of the Foreign Corrupt Practices Act. He has represented numerous corporate and individual clients before the DOJ, SEC, CFTC, OCC, FDIC, FINRA, FRB, and OFAC, as well as state attorneys general.Edward is frequently recognized by leading industry publications such as Chambers USA where he is ranked as an Up and Coming lawyer in the Litigation: White-Collar Crime & Government Investigations – New York category, and described as “smart, hard-working and sophisticated in his factual and legal analysis” and a “fantastic attorney.” He is also recommended as “one of the most experienced FCPA and securities prosecutors to come out of the government” by The Legal 500 US for Dispute Resolution: Corporate Investigations and White-Collar Criminal Defense.During his tenure in the SDNY, Edward was a senior member of the Securities & Commodities Fraud Task Force and also handled FCPA matters, including three of the largest-ever FCPA criminal resolutions. He is an accomplished trial attorney who tried more than a dozen jury trials to verdict as an Assistant U.S. Attorney. Among his trials were 10 complex, multi-week white-collar trials, including six trials in the SDNY’s Securities Fraud Unit, all of which resulted in convictions. He also argued 11 appeals in the U.S. Court of Appeals for the Second Circuit. Edward is a recipient of the Assistant Attorney General’s Exceptional Service Award.Edward is frequently published and quoted by financial publications and media outlets on white-collar and securities law developments including The Wall Street Journal, Bloomberg, Law360, New York Law Journal, and Law.com, among others. He is also a member of the Federal Bar Council, Federal Criminal Practice Committee, and the New York City Bar, White Collar Crime Committee.Prior to joining Morrison Foerster and the SDNY, Edward served as a law clerk to the Honorable Robert A. Katzmann on the U.S. Court of Appeals for the Second Circuit and the Honorable Lewis A. Kaplan on the U.S. District Court for the SDNY and was a litigation associate at two prominent New York law firms.Edward graduated magna cum laude in the top one percent of his class from Georgetown University Law Center, where he was a senior editor of the Georgetown Law Journal and elected to the Order of the Coif. Edward earned his B.A., magna cum laude, with distinction in History from Amherst College.<h4>Representative Experience</h4><h5>Defense</h5>Corporate Representations<ul><li>McKinsey & Company and McKinsey & Company Africa in a global resolution of FCPA charges arising from allegations of bribery in South Africa, with a deferred prosecution agreement with DOJ and a parallel criminal resolution with the South Africa National Prosecuting Authority.</li><li>A technology company in a multi-agency federal criminal investigation involving allegations of illegal gratuities, which included advising the company on remedial actions related to internal controls. DOJ and SEC took no action against our client.</li><li>Global financial institutions in DOJ and regulatory investigations of allegations of BSA/AML violations and sanctions evasion.</li><li>Global financial institutions in internal investigations of financial and compliance irregularities and related remediation.</li><li>A company conducting an internal investigation into alleged tax and accounting issues, which included counseling the audit committee of the board of directors on matters of corporate governance, including internal controls over financial reporting.</li><li>A multinational, publicly traded global Fortune 500 company before DOJ, SEC, and a multilateral organization in investigations of allegations of foreign bribery and corruption. DOJ and SEC took no action against our client.</li><li>An artificial intelligence company in an SDNY securities and accounting fraud investigation. The SDNY took no action against our client.</li><li>A fintech company in an SDNY criminal investigation of BSA/AML violations. The SDNY took no action against our client.</li><li>A healthcare provider in a one-week arbitration hearing concerning a medical billing dispute with a university physician practice.</li></ul>Individual Representations<ul><li>Senior executives of a public company in a DOJ and SEC accounting fraud investigation. DOJ and SEC took no action against our clients.</li><li>A senior executive of a public company in a DOJ and SEC insider trading investigation. DOJ and SEC took no action against our client.</li><li>A former executive of a global investment bank charged by DOJ with alleged FCPA and money laundering offenses arising from a financing transaction in Africa and Europe.</li><li>A senior executive of a national bank in multiple investigations by federal and state regulators and law enforcement, including SEC, DOJ, FDIC, and FINRA, and in civil class-action lawsuits alleging violations of federal securities laws.</li></ul>

Edward Imperatore

Partner

Ryne Miller is a partner in the firm’s Financial Services Group, advising global trading and markets businesses, financial institutions, and fintech companies on complex regulatory, governance, investigative, and transactional matters. He is widely sought for his experience across traditional and emerging markets, including commodities, derivatives, securities, digital assets, and prediction markets. Ryne delivers clear, commercially focused guidance to help clients achieve strategic objectives and is valued for his longstanding relationships with market participants and regulators across the trading and markets industry. Clients rely on Ryne’s deep experience with the regulatory and enforcement programs of the Commodity Futures Trading Commission (CFTC), Securities and Exchange Commission, FINRA, National Futures Association, FinCEN, Department of Justice, and other federal and state regulators. Executives consistently seek his judgment on high-stakes matters involving investigations, governance, strategic relationships and negotiations, and crisis and incident response. Ryne is a frequent speaker at trading and markets industry events, a guest lecturer at leading U.S. law and business schools, and has testified before Congress on digital asset market structure regulation. He has also participated in a CFTC roundtable on the evolution of U.S. derivatives market structure. Before joining Morrison Foerster, Ryne served as chair of the Commodities, Futures & Derivatives Group and co-chair of the Fintech, Crypto, Trading & Markets Group at another leading law firm. Earlier in his career, he was a New York-based partner and co-head of the Commodities and Derivatives practice at an Am Law 10 firm, served as legal counsel to a former chairman of the CFTC, and was general counsel to a U.S. financial services and digital assets business.