Matthew C. Solomon has significant experience in complex and high-stakes civil and criminal matters, having served for 15 years with the U.S. Department of Justice and the U.S. Securities and Exchange Commission—including most recently as the SEC’s Chief Litigation Counsel.
Matt’s practice focuses on securities enforcement, complex commercial litigation and white-collar criminal defense. He joined the firm as a partner in 2017.
Matt joined the SEC’s Enforcement Division as Deputy Chief Litigation Counsel in 2012 and was elevated to be the agency’s top litigator in 2013. As Chief Litigation Counsel, Matt led the SEC’s litigation efforts in federal courts and administrative proceedings, as conducted by 150 trial attorneys in Washington, D.C., and the SEC’s 11 regional offices. He also worked closely with SEC investigative staff nationwide in the supervision and negotiation of cases filed as settled matters, and regularly advised the Director of Enforcement and the Commission on litigation strategy and risk.
Under Matt’s leadership, the SEC prevailed in a number of high-profile federal trials, and he personally represented the agency in some of its most sensitive cases. Matt also spearheaded the SEC’s litigation response to significant legal and policy issues, such as developments in insider trading law and challenges to the SEC’s administrative courts.
Before joining the SEC, Matt served in several prominent positions with the DOJ, including as an Assistant U.S. Attorney and then Chief of the Fraud Unit for the U.S. Attorney’s Office for the District of Columbia, as a DOJ detailee-counsel to the Senate Judiciary Committee, and as an Honors Program trial lawyer in the Criminal Division’s Public Integrity Section.
Matt’s prosecutions at DOJ included convictions in a number of high-profile cases, including NASA’s former Chief of Staff in a week-long corruption jury trial in the District for the District of Columbia; two highly placed political party operatives in a six-week tax and corruption jury trial in the District of Puerto Rico; an IRS Special Agent in a two-week corruption jury trial in the Northern District of California; and a federal congressional candidate and sitting state legislator who both pleaded guilty to federal campaign finance abuses.
An electronic securities trading firm in connection with an SEC investigation into various trading practices.
A global Asia-headquartered financial institution in connection with CFTC-regulated “spoofing” conduct.
A global European-based financial institution in connection with an SEC and CFTC collateral consequences analysis stemming from DOJ and SEC resolutions.
A Fortune 100 company in connection with an SEC accounting fraud investigation.
A hedge fund with over $25 billion AUM in connection with insider trading training and compliance advice.
A hedge fund with over $10 billion in AUM in connection with advice concerning expense allocation issues related to side pocket agreements.
An independent valuation firm in connection with a review of valuation policies and procedures.
A private wealth management firm with a large portfolio of public and private investments in connection with a review of internal policies and procedures, to include whistleblower protections.
An electronics securities trading firm in connection with a FINRA inquiry into possible insider trading.
An international hospitality company in connection with its policies and procedures as they relate to the treatment of U.S. public officials.
A subject in DOJ and SEC investigations of potential violations of the Foreign Corrupt Practices Act.
A witness in a high-profile federal public corruption trial.
Barrister, Edward Bennett Williams Inn of Court
- “Second Circuit Clarifies “Meaningfully Close Relationship” No Longer Required To Prove Insider Trading Under Gift Theory,” (co-author with Jonathan Kolodner and Alexander Janghorbani), Cleary Gottlieb Alert Memo, August 24, 2017
- “Cleary Gottlieb Discusses Federal Spoofing Conviction,” (co-author with Lewis Liman and Jonathan Kolodner), The CLS Blue Sky Blog, August 16, 2017
- “Supreme Court Applies Five-Year Statute of Limitations to SEC Disgorgement Claims,” (co-author with Lewis Liman and Alexander Janghorbani), Harvard Law School Forum on Corporate Governance and Financial Regulation, June 7, 2017
- “Fate of the SEC In-House Court: Careful What You Wish For,” (co-author with Alexander Janghorbani and Richard Cipolla), Law360, May 23, 2017
- “SEC, Hungarian Executives Settle 5-Year FCPA Suit that Generated Government-Friendly Rulings on Threshold Legal Issues,” (co-author with Lisa Vicens, Jessica Dwinell and Jenny Paul), Cleary M&A and Corporate Governance Watch Blog, April 28, 2017
- “Acting SEC Chair’s Steps to Centralize the Process of Issuing Formal Orders—Are Commentators Drawing the Right Lessons?” (co-author with Lisa Vicens), Harvard Law School Forum on Corporate Governance and Financial Regulation, March 13, 2017
- “GC Whistleblowing And Other Implications From Bio-Rad,” Law360, February 28, 2017
- American Investment Council’s General Counsels Day, Washington, D.C., November 8, 2017
- The Conference Board’s Governance Watch – Recent Whistleblower Issues Webcast, New York, NY, September 12, 2017
- American Investment Council: Chief Compliance Officers Working Group Meeting, “Tax Issues and SEC Enforcement in a Post-Kokesh World” (Boston, MA), Panelist, June 28, 2017
- Annual SEC/DOJ Enforcement 2017 Update, Panelist, June 2017
- “Insider Trading - Practical Considerations in Prosecuting and Defending Cases After Salman” panel discussion, sponsored by the Broker-Dealer Regulation and SEC Enforcement Committee of the D.C. Bar Corporation, Finance and Securities Law Section, Washington, D.C., February 2017
- “Litigating Insider Trading Cases: Lessons Learned from Recent Trials,” panel, June 2016
- U.S. Securities and Exchange Commission’s 26th Annual International Institute for Securities Market Development, Presenter, “Remedies and Sanctions for Securities Law Violations,” Washington, D.C., April 2016
- SIFMA Compliance and Legal Society Annual Seminar, Panelist, “Handling a Regulatory Investigation,” Orlando, FL, March 2016
- The SEC Speaks in 2016, Featured Speaker, “Enforcement” panel, Washington, D.C., February 2016
- Foreign Corrupt Practices Act and International Anti-Corruption Developments (PLI), Panelist, “Litigating FCPA Cases,” New York, NY, May 2015
- Edward Bennett Williams Inn of Court, Panelist, “Financial Crimes,” Washington, D.C., March 2015
- The SEC Speaks in 2015, Featured Speaker, “Enforcement” panel, Washington, D.C., February 2015
- Columbia Law School Securities Law Institute, Panelist, “Current Issues in Securities Regulation: The Hot Topics,” New York, NY, November 2014
- 38th Annual Southwest Securities Conference, Panelist, “Summary of Significant Regulatory Litigation,” Dallas, TX, August 2014
- District of Columbia Bar Association, Panelist, “Defending a White-Collar Criminal Case,” Washington, D.C., June 2014
- Sandpiper Partners, LLC, Panelist, “Economic Crime in the Digital Age: Latest Developments in Fraud, Anti-Corruption and Cyber Crime,” Philadelphia, PA, May 2014
- Federal Bar Counsel Securities Law Section, Executive Council, Featured Speaker, Washington, D.C., March 2014
- The SEC Speaks in 2014, Featured Speaker, “Enforcement” panel, Washington, D.C., February 2014
- Sandpiper Partners, LLC, Panelist, “Annual Securities Litigation and 2013 Update,” Washington, D.C., April 2013
- O’Melveny & Myers LLP, Panelist, “Anti-Corruption Trends Impacting Companies Doing Business in India,” Washington, D.C., March 2013
- Boston Bar Association, Panelist, “Foreign Corrupt Practices Act,” Boston, MA, February 2013