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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

  • Lead counsel representing Fortune 50 consumer products and medical devices company in an ongoing SEC investigation into accounting, SEC disclosure and insider trading allegations.
  • Leading representation of Fortune 50 consumer products company in an ongoing SEC investigation into its revenue recognition practices.
  • Lead counsel representing Fortune 500 technology company in an ongoing SEC investigation into its securities registration and SEC disclosure practices.
  • Leading representation of Fortune 500 technology company in an ongoing SEC investigation into SEC disclosure relating to cyber breaches.
  • Leading representation of former General Counsel of a regional bank in ongoing SEC and DOJ investigations into SEC disclosure relating to related party transactions.
  • Representing executive of private equity firm in an SEC investigation into accounting and SEC disclosure practices at portfolio company.
  • Lead counsel representing U.S. issuer in FCPA investigation by the SEC relating to alleged bribery by operating subsidiary in Israel.
  • Lead counsel representing U.S. issuer in multiple SEC investigations of securities offerings.
  • Representing a regional bank in an ongoing investigation into its accounting and disclosure for bad debt.

Representative U.S. Government Enforcement Resolutions

  • Secured negligence-based settlement with the SEC in 2020 on behalf of a multinational pharmaceutical manufacturer following an investigation into accounting and disclosure practices.
  • Secured 2020 declination from the DOJ and favorable settlement with the SEC following multi-year FCPA investigations into alleged bribery in multiple countries.
  • Represented a former executive of Diageo plc in an 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 alleged efforts to take control 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)