O’Melveny Worldwide

Todd M. Beaton, Jr.

Partner

New York Office
Areas of Focus
Areas of Focus
Financial Services Regulation
Regulatory & Advisory
Securities Enforcement
Securities Regulation
Overview Experience Insights News Credentials

Todd focuses his practice on regulatory enforcement defense. He represents financial institutions, broker-dealers, investment advisers, hedge funds, audit firms, public companies, and corporate officers in regulatory inquiries, investigations, and enforcement matters involving the US Securities and Exchange Commission (SEC), the US Department of Justice (DOJ), the Financial Industry Regulatory Authority (FINRA) and other self-regulatory organizations (SROs), the New York State Department of Financial Services, the Federal Reserve Bank of New York, and other federal and state regulators.

Todd joined O’Melveny from an international law firm, where he was a partner in the firm’s securities enforcement and regulatory defense practice. Previously, he served as a Chief Counsel in FINRA’s Enforcement Department, focusing on matters originating from FINRA’s Market Regulation team. He worked closely on matters involving the Market Access Rule, best execution, Regulation SHO, market manipulation, and trade reporting rules, among others, and brought enforcement matters on behalf of FINRA and other SROs, including the New York Stock Exchange, Cboe, and Nasdaq.

Earlier in his career, Todd clerked for the Honorable Richard K. Eaton of the US Court of International Trade from 2005 to 2007.

  • Represented a broker-dealer in the largest enforcement action brought by the SEC involving compliance with the customer protection rule (Rule15c3-3).
  • Represented a large financial institution in an SEC inquiry regarding asset-backed securities trading and TRACE reporting.
  • Represented a large financial institution in responding to separate government inquiries regarding secondary mortgage-backed securities trading.
  • Represented a large financial institution in responding to separate government inquiries regarding FX trading business.
  • Represented investment advisers in connection with government inquiries regarding insider trading and other issues.
  • Represented a large investment adviser in a SEC inquiry regarding marketing disclosures and valuation of illiquid securities.
  • Represented a US insurance company in responding to inquiries from the New York State Department of Financial Services.
  • Represented a financial institution in an SEC investigation regarding synthetic collateralized debt obligations squared.
  • Represented a financial institution in a FINRA inquiry regarding broker-dealer anti-money laundering surveillance and reporting requirements.

Admissions

Bar Admissions

  • New York

Court Admissions

  • US District Court, Southern District of New York

Education

  • Albany Law School, JD, magna cum laude, 2005
  • Union College, BA, with honors, 2002

Honors & Awards

  • Recognized by Chambers USA for Financial Services Regulation: Broker Dealer (Enforcement) (2026)

Professional Activities

Speaker

  • “Lessons Learned in Capital Markets: Enforcement Trends & Takeaways,” SIFMA Compliance and Legal Society Annual Seminar (March 2025)

Panelist

  • “Litigation and Regulatory Enforcement: Perspectives from External Counsel, In-House Counsel, and Regulators,” SIFMA Compliance & Legal Society New York Regional Seminar (October 2023)

Author

  • “NYDFS Issues Guidance on Third-Party Cybersecurity Risk Management: What Regulated Entities Need to Know,” Password Protected (November 2025)
  • “FinCEN Hits Pause: AML Rule for Investment Advisers Delayed,” Subject to Inquiry (July 2025)

Co-Author

  • "Expert Analysis: A Primer on NYDFS’ 3rd-Party Cybersecurity Guidance," Law360 (December 2025)
  • “Principal Lessons of the Jesse Litvak Securities Fraud Saga,” Westlaw Journal (April 2019)
  • “‘Dark Pool’ Trading is Not Shielded from Regulatory Spotlight,” New York Law Journal (January 2013)
  • “Analyzing the SEC’s First Deferred Prosecution Agreement,” New York Law Journal (July 2011)
  • “Expert Testimony and Class Certification: The Outcome Determinative Role of Daubert,” ALI-ABA (2008)

Contributor

  • “Chapter 61: Litigation Management by Corporations,” Commercial Litigation in New York State Courts, Third Edition, Vol. 4A (2010)
  • “Chapter 10: The Planning Process,” Successful Partnering Between Inside and Outside Counsel, Vol. 1 (Supplement) (2011)

Clerkships

  • The Honorable Richard K. Eaton, US Court of International Trade (2005-2007)
Related Practices
Financial Services Regulation
Regulatory & Advisory
Securities Enforcement
Securities Regulation
Related Industries
Banking & Financial Services
Fintech