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A former Associate Director for the U.S. Securities and Exchange Commission’s Enforcement Division (SEC), Gerald Hodgkins has a broad regulatory enforcement practice focused on representing financial institutions, public companies and individuals in investigations and enforcement actions brought by the key financial regulators. Mr. Hodgkins has extensive experience in matters pertaining to the SEC, with particular focus on broker-dealer and investment adviser regulation, public company accounting and U.S. anti-corruption law. He also has represented clients in matters before the Public Company Accounting Oversight Board (PCAOB).

Representative Ongoing Engagements

  • Representing Fortune 500 technology company in an ongoing SEC investigation into its securities registration and SEC disclosure practices.
  • Representing U.S. bank in SEC investigation related to financial disclosure.
  • Conducting internal investigation for Fortune 500 company regarding accounting practices.
  • Representing former General Counsel of a regional bank in ongoing SEC and DOJ investigations into SEC disclosure of related party transactions.
  • Representing executive of private equity firm in an SEC investigation into accounting and financial disclosure at portfolio company.
  • Representing U.S. issuer in FCPA investigation by the SEC related to alleged bribery by operating subsidiary in Israel.
  • Representing a regional bank in an ongoing investigation into its accounting and disclosure for bad debt.

Representative U.S. Government Enforcement Declinations and Resolutions

  • Served as lead counsel representing Fortune 50 consumer products and medical devices company in an SEC investigation into accounting, financial disclosure and insider trading allegations. Matter was closed without enforcement action in 2020.
  • Led representation of Fortune 50 consumer products company in an SEC investigation into its revenue recognition practices. Matter was closed in 2020 without enforcement action taken.
  • Represented Fortune 500 technology company in an SEC investigation into SEC disclosure relating to cyber breaches. Matter was closed without enforcement action in 2020.
  • Secured 2020 declination from the DOJ and favorable settlement with the SEC following multi-year FCPA investigations into alleged bribery in multiple countries.
  • Served as lead counsel representing U.S. issuer in multiple SEC investigations of securities offerings. Matters were closed in 2020 without enforcement action taken.
  • Secured negligence-based settlement with the SEC in 2020 on behalf of a multinational pharmaceutical manufacturer following an investigation into accounting and disclosure practices.
  • Counsel for registered representative of municipal securities dealer in an SEC investigation regarding allegations of illegally “parking” securities with customer. Matter was closed in 2020 without enforcement action taken.
  • Represented a former executive of Diageo plc in an SEC investigation related to the company's revenue recognition practices. Diageo settlement announced in 2020 but no charges were brought against client.
  • Secured favorable settlement with the SEC in 2020 on behalf of software developer who sold cryptocurrency in an initial coin offering (“ICO”).
  • Secured negligence-based settlement with the SEC in 2020 on behalf of private investment firm and its principal following an investigation into the firm's SEC disclosures relating to its acquisition of stock of a publicly traded company.
  • Successfully petitioned the SEC in 2020 for removal of collateral industry bars imposed on principal of private investment firm as part of an earlier settlement.
  • Secured 2019 settlement with the SEC on behalf of registered investment adviser as part of the SEC’s Share Class Selection Disclosure Initiative.
  • Secured negligence-based settlement with the SEC in 2019 on behalf of marketplace lender following an investigation into alleged inaccuracies in lender’s disclosure to investors.
  • Secured declination from the DOJ in 2019 following FCPA investigations into alleged bribery in the Middle East. SEC investigation also was closed without any enforcement action taken.
  • Successfully petitioned PCAOB in 2019 to change its policy relating to disclosure of audit clients in enforcement orders against public company auditors.
  • Conducted internal investigation on behalf of Fortune 50 company related to potential violations by external auditor of the SEC’s auditor independence rules.
  • Conducted internal investigation on behalf of engineering firm related to possible bribery in Asia.
  • On behalf of investment banks in capital market transactions, conducted due diligence relating to pending SEC investigations of issuers.

Previous Experience

  • U.S. Securities and Exchange Commission
    • Associate Director (2010-2017)
    • Assistant Director (2007-2010)
    • Branch Chief (1999-2007)
    • Staff Attorney (1997-1999)