Adam S. Aderton is Co-Chair of Willkie’s Securities Enforcement Practice Group and partner in the Litigation and Asset Management Departments. His practice focuses on regulatory enforcement matters and white-collar defense. Adam has particular experience in regulatory inquiries and litigation involving the asset management industry, including matters involving private equity funds, hedge funds, venture capital funds, mutual funds, ETFs, business development companies, and separately managed accounts. In addition to representing clients in connection with SEC and other government examinations, investigations, and litigations, Adam provides compliance counseling to asset managers. Before joining Willkie, Adam served in the SEC’s Division of Enforcement for over 14 years, including as Co-Chief of Enforcement’s Asset Management Unit from 2019 to 2022, where he directed SEC investigative teams across the country responsible for investigations and litigation involving the asset management industry.
Experience
Adam previously served as Co-Chief of the Asset Management Unit in the Division of Enforcement of the U.S. Securities and Exchange Commission (SEC), where he led investigations resulting in many of the SEC’s most significant asset management enforcement actions, including actions involving undisclosed conflicts of interest at one of the world’s largest hedge funds, allegations of a billion-dollar fraudulent fund valuation scheme, and numerous actions involving the disclosure of conflicts of interest. Adam also led Enforcement’s coordination with the Division of Examinations and represented Enforcement on significant rulemakings involving the asset management industry. Prior to joining the SEC in 2008, Adam practiced at an international law firm.
- “SEC Enforcement – Top Four Developments from July 2024,” Harvard Law School Forum on Corporate Governance, September 12, 2024
- “SEC Enforcement – Top Seven Developments from June 2024,” Harvard Law School Forum on Corporate Governance, August 22, 2024
- “Court Dismisses Securities and Exchange Commission’s Novel Cybersecurity Claim Against SolarWinds,” The Computer & Internet Lawyer, October 2024
- Representing a registered investment adviser in an SEC investigation involving the calculation of private equity fund management fees.
- Representing a registered investment adviser in an SEC investigation involving revenue-sharing arrangements.
- Representing a registered investment adviser in an SEC investigation involving the pay-to-play rules.
- Representing a registered investment adviser and an executive in an SEC investigation involving the marketing rule.
- Representing an information services provider in an SEC investigation involving marketing materials.
- Representing a software company CEO in an SEC investigation involving crypto asset registration.
- Representing a registered investment adviser in an SEC investigation involving the SEC whistleblower rules.
- Representing an executive in an SEC investigation involving fee and expense issues at a registered investment adviser.
- Representing a registered investment adviser in an SEC investigation involving material non-public information controls.
- Representing executives in an SEC investigation involving off-channel communications.
- Represented a registered investment adviser in an SEC investigation involving block trading practices. The investigation was terminated with no action against our client.
- Represented a trader in an SEC investigation involving collateralized mortgage obligations. The investigation was terminated with no action against our client.
- Represented a registered investment adviser in an SEC investigation involving material non-public information controls. The investigation was terminated with no action against our client.
- Represented an investment adviser and its principal in an SEC investigation involving alleged undisclosed conflicts of interest. The investigation was terminated with no action against our client.
- Represented a registered investment adviser in an SEC investigation involving off-channel communications.
- Conducted an internal investigation involving allegations of misrepresentation of investment strategy against a registered investment adviser.
- Conducted an internal investigation involving allegations of failure to enforce information barriers against a registered investment adviser.
- Conducted an internal investigation involving SEC filings by a registered investment adviser.
Credentials
Education
University of Virginia School of Law, J.D., Order of the Coif; Editor, Virginia Law Review, 2004 Truman State University, B.A., 2001