Alexander Janghorbani’s practice focuses on complex securities issues, litigation and enforcement, informed by nearly nine years of service with the U.S. Securities and Exchange Commission.

From 2008 through 2016, Alex served on the investigative staff and as a senior litigator in the SEC’s New York Regional Office. During that time, he litigated high-profile and national-priority cases, including one of the few jury trials to come out of the 2008 financial crisis, and undertook major investigations such as one of the SEC’s largest-ever Foreign Corrupt Practices Act actions.

From 2010 through 2016, Alex served as Senior Trial Counsel in the SEC’s Division of Enforcement. In that role, he was lead counsel on multiple trials and hearings in U.S. district courts and SEC administrative proceedings. Alex was responsible for leading the SEC’s enforcement efforts in cases involving market manipulation, insider trading, accounting fraud, false disclosure and offering frauds. In particular, his practice focused on the investment adviser space, bringing actions involving mutual funds, hedge funds and individual investment advisers for undisclosed conflicts of interest, false and misleading statements concerning assets under management, undisclosed revenue-sharing arrangements, client favoritism, and misleading advertising.

While at the SEC, Alex also handled many other investigative matters, including significant FCPA cases, actions against broker-dealers for violations of antifraud and registration provisions, unregistered securities offerings, and other fraud and regulatory matters.

In his cases, Alex worked closely with attorneys from SEC investigative units, including the Asset Management Unit and Market Abuse Unit, as well as attorneys at the U.S. Department of Justice’s Fraud Section, various U.S. Attorney’s offices, the Manhattan District Attorney’s office and foreign securities regulators.

Alex joined the firm in 2003, left to join the SEC in 2007 and returned to the firm as a senior attorney in 2017.

Notable Experiences

  • Petrobras in parallel DOJ/SEC and class action matters arising out of investigations of corruption in contracting by the Brazilian prosecutors.

  • ING in investigation and settlement with NYSE concerning ADR trading.

  • OPKO Health, Inc. in SEC enforcement action, a number of securities class actions, and shareholder derivative actions concerning an alleged pump-and-dump scheme involving investments made by the company, its CEO, and certain other entities and individuals.

  • Fortune 100 company in connection with SEC accounting fraud investigation.

  • Fortune 100 company in connection with SEC investigation of Regulation FD disclosures.

  • Registered investment adviser to a private fund in connection with an SEC investigation into valuation and disclosure issues.

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5th Circuit Decision Further Undermines Use of Administrative Courts for SEC Enforcement Actions and Provides Fresh Ammunition to SEC Rulemaking Challenges,” Westlaw Today, June 17, 2022 (with Matthew C. Solomon, Tom Bednar, and Jackie Brune)

SEC Nearly Doubles Size of Digital Asset Enforcement Team,” Cleary Cybersecurity and Privacy Watch blog post, May 4, 2022 (with David Lopez, Matthew C. Solomon, Tom Bednar, and Samuel Levander)

2021 Developments in Securities and M&A Litigation,” Cleary Gottlieb Alert Memorandum, January 18, 2022 (with Joon H. Kim, Matthew C. Solomon, Victor L. Hou, Roger A. Cooper, Lisa Vicens, Jared Gerber, Rishi N. Zutshi, Nowell D. Bamberger, Abena Mainoo, Rahul Mukhi, Lina Bensman, Mark E. McDonald, Anthony M. Shults, Avion A. Tai, and Chelsea Hanlock)

SEC Charges Eight Companies and Signals Need for Better Disclosures About Delayed Filings,” Cleary Gottlieb Alert Memorandum, May 6, 2021 (with Nicolas Grabar, David Lopez, Fernando A. Martinez and Matthew C. Solomon)

Despite Disagreements, SEC Commissioners Emphasize Need for Clear Disclosure by ESG Funds,” Cleary Enforcement Watch blog post, September 24, 2020 (with Robin M. Bergen and John Lightbourne)

OCIE Risk Alert Reinforces Key Focus Areas for Private Funds,” Cleary Gottlieb Alert Memorandum, June 26, 2020 (with Robin M. Bergen, John Anderson Lightbourne and Zachary L. Baum); republished by the New York University School of Law Compliance & Enforcement Blog

Supreme Court Upholds, with Limits, the SEC’s Authority to Seek Disgorgement,” Cleary Gottlieb Alert Memorandum, June 25, 2020 (with Breon S. Peace, Robin M. Bergen and Matthew C. Solomon)

SEC Proposes Overhaul of Advertising and Solicitation Rules for Investment Advisers,” Cleary Gottlieb Alert Memorandum, November 18, 2019 (with Richard S. Lincer, Adrian Rae Leipsic, and Robin M. Bergen)

Headwinds and Shifting Priorities: Beyond the Numbers In The SEC Enforcement Division’s 2019 Annual Report,” Cleary Enforcement Watch blog, November 11, 2019 (with Robin M. Bergen, Matthew C. Solomon, Alex Janghorbani, Jenny Paul, and Samuel H. Chang); republished by the NYU Compliance & Enforcement blog

SEC and CFTC Chairs Sign Enhanced Multilateral Memorandum of Understanding Expanding Cross-Border Enforcement Cooperation,&rdquo Cleary Enforcement Watch blog, June 3, 2019 (with Breon Peace, Nowell D. Bamberger, Martine B. Forneret, and Alison Bitterly)

CFTC Enforcement Division Issues New Advisory on Self-Reporting and Cooperation,” Cleary Enforcement Watch blog post, Marcy 15, 2019 (with Nowell D. Bamberger and Samantha Del Duca)

CFTC Issues First Whistleblower Award Originating From Both a Related Action and a Company Outsider,” Cleary Enforcement Watch blog, March 11, 2019; republished by Law360, April 2, 2019; republished by Harvard Law School Forum on Corporate Governance and Financial Regulation, March 26, 2019 (with Jennifer Kennedy Park, Nowell D. Bamberger and Jim Wintering)

SEC Issues First ICO Enforcement Action Against a Self-Reporting Token Issuer,” Cleary Enforcement Watch blog, February 28, 2019; republished by Law360, and the Harvard Law School Forum on Corporate Governance and Financial Regulation, March 12, 2019 (with Pam Marcogliese, Matthew C. Solomon and Jim Wintering)

SEC Announces Enforcement Cases on Public Company Internal Controls,” Cleary Gottlieb Alert Memorandum, February 5, 2019; republished by Law360, March 4, 2019, and Harvard Law School Forum on Corporate Governance and Financial Regulation, March 7, 2019 (with Nicolas Grabar, Sandra L. Flow, Alejandro Canelas Fernandez, and Tapan R. Oza)

DOJ Issues Twelfth Declination Letter Under FCPA Cooperation Policy,” Cleary Enforcement Watch blog, February 19, 2019 (with Jennifer Kennedy Park and Thomas Galvão Graham)

Second Circuit Denies Gupta Appeal of Insider Trading Conviction—Continuing to Give Broad Meaning to “Personal Benefit” Requirement,” NYU Compliance and Enforcement Blog, January 17, 2019 (with Joon H. Kim, Jennifer Kennedy Park, and Nowell D. Bamberger)

Tenth Circuit Affirms Ruling Allowing SEC to Bring Securities Fraud Claims Over Certain Foreign Transactions,” Cleary Gottlieb Alert Memorandum, January 30, 2019 (With Les Silverman, Abena Mainoo, and Matthew C. Solomon)

SEC Sanctions ADT Over Non-GAAP Financial Measures in Earnings Releases,” Cleary Gottlieb Alert Memorandum, January 9, 2019 (with Les Silverman, Nicolas Grabar, and Matthew C. Solomon)

Government Moves to Voluntarily Dismiss Remaining Charge Against Jesse Litvak, Foregoing a Third Trial,” Cleary Enforcement Watch blog, July 31, 2018 (with Joon H. Kim, Jennifer Kennedy Park and Nowell D. Bamberger)

Supreme Court Ruling on SEC-Appointed Judges,” Harvard Law School Forum on Corporate Governance and Financial Regulation, July 16, 2018 (with Matthew Solomon)

Kokesh and Its Impact on SEC Enforcement, a Year Later,” Law360, June 4, 2018 (with Matthew Solomon and Michael Heckmann)

SEC Proposes New Best Interest Standard for Broker-Dealers and “Clarification” of Existing Fiduciary Standard for Investment Advisers,” Cleary Gottlieb Alert Memorandum, May 2, 2018 (with Robin M. Bergen, Carl F. Emigholz, Arthur H. Kohn and Colin D. Lloyd)

Supreme Court Grants Certiorari on the Constitutionality of SEC ALJ Appointments–What This Means for the Securities Industry” (with Matthew Solomon and Richard Cipolla), Cleary Enforcement Watch, January 16, 2018; republished by the Compliance & Enforcement blog from the Program on Corporate Compliance and Enforcement and New York University School of Law, January 24, 2018. 

Supreme Court Applies Five-Year Statute of Limitations to SEC Disgorgement Claims,” Cleary Gottlieb Alert Memorandum, June 6, 2017.

Fate of the SEC In-House Court: Careful What You Wish For” (with Matthew Solomon and Richard Cipolla), Law360, May 23, 2017.

District Judge Rules That Dodd-Frank Allows SEC to Bring Securities Fraud Claims Over Certain Foreign Transactions” (with Lewis Liman, Lisa Vicens, and Amanda Ravich) April 3, 2017.

Acting SEC Chair Michael Piwowar Takes Steps to Centralize the Process of Issuing Formal Orders – Are Commentators Drawing the Right Lessons?” (with Matthew Solomon, Lisa Vicens, and Mark McDonald), Cleary M&A and Corporate Governance Watch blog, February 28, 2017.