Verified profile

Bill Martin

Counsel | Regulatory Investigations, Litigation

Bill Martin's profile photo
LocationNew YorkNew York, United States
Current roleCounsel, White Collar Defense & Corporate Investigations GroupO'Melveny & Myers LLP · since Apr 2019
Government service8yrsSecurities and Exchange Commission (SEC) · Court of Appeals for the Second Circuit · U.S. District Court · U.S. Congress (Other)

About

Bill Martin’s nearly two decades of government and private practice experience enables him to guide financial services companies, blockchain and other fintech companies, audit and special committees, officers and directors, and others in connection with internal investigations, government and regulatory inquiries and enforcement actions, and litigation.

A former senior counsel in the US Securities and Exchange Commission’s Market Abuse Unit, Bill has investigated and prosecuted securities cases involving insider trading, market-structure practices, the Foreign Corrupt Practices Act (FCPA), failure to supervise, investment advisors, and cybersecurity. In these matters, Bill worked closely with the Justice Department, FBI, IRS, FINRA, and other regulators.

Before entering public service, Bill spent six years in the litigation practice of a major New York law firm, advising clients in shareholder derivative and securities litigation and investigations. He frequently advised on cross-border matters and on litigation involving accounting fraud, internal controls, and other issues connected to the FCPA.

Roles

Apr 2019–Present
Current role

Counsel, White Collar Defense & Corporate Investigations Group

O'Melveny & Myers LLP

New York, New York

Civil LitigationConsultingEnforcementRegulatory SpecialistLegal Officers and PractitionersWhite Collar CrimeLitigation Support SpecialistCriminal LawCorporate Law

Defends financial services companies, digital assets and other fintech companies, and executives in DOJ, SEC, CFTC and state regulatory investigations, as well as private litigation.

Analyzed potential legal and regulatory risks of specific digital assets on behalf of range of clients in digital assets industry.

Successfully defended registered investment adviser affiliated with national bank and individual employee in FINRA investigation.

Represented and prepared individual subpoenaed to testify in criminal securities fraud trial.

Led multiple rounds of briefing and 4 oral arguments for large pro bono team in D.D.C. immigration case.

Jan 2015–Mar 2019
Former role

Senior Counsel

Securities and Exchange Commission (SEC), Enforcement | Market Abuse Unit

New York

Foreign Corrupt Practices Act (FCPA)International Trade LawEnforcementSecurities LawCriminal LawCriminal Investigation

Obtained over $134 million in settlements with 5 entities, including depositary banks and broker-dealer firms, as well as 2 and individuals, involved in the practice of improperly pre-releasing ADRs.

Charged recidivist company with FCPA internal accounting controls and books and records violations in India, China and Kuwait; obtained $7.8 million penalty.

Charged two individuals with civil insider trading in excess of $40 million. After verdicts in parallel criminal case, reached settlements with both defendants providing monetary and injunctive relief.

Charged broker-dealer and investment adviser with Safeguard Rule of Regulation S-P violation after data breach involving over 330,000 customer households. Obtained $1 million penalty, the largest to date for this violation. Additionally, after parallel criminal investigation, obtained 5-year industry bar based on criminal conviction against former financial advisor who caused data breach.

After parallel criminal investigation, charged former investment adviser with $20 million securities and investment advisor fraud on clients. Separately obtained lifetime industry bar based on criminal conviction and 5-year prison sentence.

Responsibilities include developing investigative plans, interviewing and taking testimony from witnesses, drafting memos recommending that the Commission enter formal orders of investigation or authorize or institute proceedings and negotiating settlement of SEC charges against firms or individuals.

Paul R. Carey Award winner in recognition of pre-released ADR cases: SEC Chairman annually recognizes staff across agency for their exceptional personal commitment and effectiveness in working on a significant official matter.

Three-time winner of Director of Enforcement Division Award in recognition of outstanding work on Walters, ITG and Morgan Stanley Smith Barney / Galen Marsh matters.

Sep 2008–Jan 2015
Former role

Associate, Litigation Department

Wachtell, Lipton, Rosen & Katz

New York, New York

Civil LitigationCriminal DefenseWhite Collar CrimeCorporate LawTax Law

Deposed expert (former bankruptcy judge) in case alleging $500 million+ in damages; defended rebuttal expert in deposition; second-chaired other expert depositions; drafted expert reports, proposed jury charge, motions in limine and jury simulation materials.

Represented foreign bank in cross-border tax fraud in DOJ, SEC & IRS investigations; prepared for trial on enforcement of IRS “John Doe” summons; drafted and coordinated successful implementation of settlement agreements.

Represented U.S. bank in separate investigations by DOJ, OCC, Federal Reserve, FDIC, multiple state AGs and congressional committees into alleged foreclosure and mortgage servicing deficiencies. Interviewed current and former bank employees and negotiated OCC and Federal Reserve settlements.

Defended major NY corporation against shareholder 10(b), derivative and books and records cases brought against in state and federal court for potential FCPA violations and/or rejected merger offer. Won five dismissals.

Aug 2007–Aug 2008
Former role

Law Clerk

Court of Appeals for the Second Circuit

(appointed)New York

Law ClerkResearchLegal Assistant

Served as judicial law clerk to the Honorable Judge Chester Straub, researching and drafting opinions, orders, and bench memoranda.

Sep 2006–Aug 2007
Former role

Associate, Litigation Department

Simpson Thacher & Bartlett LLP

New York, New York

Legal Assistant
Sep 2005–Sep 2006
Former role

Law Clerk

U.S. District Court

(appointed)New York

ResearchLegal Assistant

Served as judicial law clerk to the Honorable Judge P. Kevin Castel, researching and drafting opinions, orders, and bench memoranda.

Jun 2003–Aug 2003
Former role

Summer Associate

Proskauer Rose LLP

New York, New York

ResearchLegal Assistant
May 1999–Aug 2000
Former role

Legislative Assistant

U.S. Congress (Other), U.S. Rep. Bill Luther (D-MN)

(appointed)District of Columbia

Legal Assistant
Jun 1998–May 1999
Former role

Paralegal Specialist

U.S. Department of Justice (DOJ), Antitrust Division, Telecommunications Task Force

(appointed)District of Columbia

ResearchParalegal Specialist

Representative matters

Private Practice Experience

March 2025

Representing one of the largest digital-assets trading platforms in enforcement investigations by the Securities and Exchange Commission into potential registration violations Advising digital-assets trading platforms and digital-assets project teams on potential legal and regulatory issues Representing digital-assets project teams in investigations by DOJ, SEC and state financial services regulators Represented a US bank in FINRA investigation into business referral practices of investment adviser affiliate; FINRA closed matter with no action taken Represented a global bank in DOJ, SEC, and IRS investigations into cross-border tax fraud Represented a US bank in separate investigations by DOJ, OCC, the Federal Reserve, FDIC, multiple state AGs, and congressional committees into alleged foreclosure and mortgage-servicing deficiencies Defended a Fortune 500 company against shareholder securities fraud claims, derivative and books-and-records cases brought against it in state and federal court relating to potential FCPA violations and a rejected merger offer; won five dismissals

Selected Government Experience

March 2025

FCPA, internal accounting controls, and books-and-records action related to conduct in India, China, and Kuwait Insider trading action with profits in excess of $40 million Investigated and led enforcement action charging antifraud violations of the Securities Exchange Act of 1934 and the Investment Advisers Act of 1940

Recognition

Honors

Director of Enforcement Division Award

Securities and Exchange Commission

March 2025

Three-time recipient of Director of Enforcement Division Award, Securities and Exchange Commission

Paul R. Carey Award

Securities and Exchange Commission

March 2025

Publications & speeches

"Centralized Exchanges," Chapter 3, Legal Matters in Web 3: A Desk Reference

The University of Chicago Law School Chicago

September 2024

Link

What the SEC’s Investigation of SolarWinds Means for CISOs and Cybersecurity Disclosures

CPO Magazine

August 2023

Link

Decentralized Autonomous Organizations (DAOs): Overview

Thomson Reuters Practical Law

November 2022

Dismantling the SEC’s Federal Court Disgorgement Authority

New York Law Journal

January 2020

SEC Establishes New Unit to Combat Cyber Misconduct and Protect Emerging Technology Retail Investors

O'Melveny & Myers LLP

February 2025

Link

President Trump Issues Executive Order to Establish Digital Assets Regulatory Framework

O'Melveny & Myers LLP

February 2025

Link

In the “Shadow” of Panuwat: SEC Insider Trading Unit Alumni Discuss Compliance Considerations Following Successful Shadow Trading Enforcement Action

Practising Law Institute

January 2024

Speaker