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.
“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.