O’Melveny Worldwide

Bill Martin’s 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.

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Private Practice Experience

  • Representing a US broker-dealer against hedge fund plaintiff asserting market manipulation claims based on alleged cross-border spoofing scheme by customers
  • Conducted an internal investigation into potential accounting issues on behalf of the Audit Committee of a public video technology company
  • Represented one of the largest digital-assets trading platforms in enforcement investigations by the Securities and Exchange Commission into potential registration violations
  • Advised digital-assets trading platforms and digital-assets project teams on potential legal and regulatory issues
  • Represented 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

  • 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

Admissions

Bar Admissions

  • New York

Court Admissions

  • US Court of Appeals, Second Circuit
  • US District Court, Eastern and Southern Districts of New York

Education

  • University of Chicago Law School, J.D., with honors; Comment Editor, University of Chicago Law Review
  • Princeton University, Princeton School of Public and International Affairs, M.P.A., Domestic Public Policy
  • Carleton College, B.A., magna cum laude, Economics and Political Economy

Honors & Awards

  • Three-time recipient of Director of Enforcement Division Award, Securities and Exchange Commission
  • Paul R. Carey Award, Securities and Exchange Commission

Professional Activities

Clerkships

  • Honorable Chester J. Straub, US Court of Appeals, Second Circuit
  • Honorable P. Kevin Castel, US District Court, Southern District of New York

Author

Speaker

  • “In the “Shadow” of Panuwat: SEC Insider Trading Unit Alumni Discuss Compliance Considerations Following Successful Shadow Trading Enforcement Action,” Practising Law Institute (June 11, 2024)

Corporate & Government Experience

  • Senior Counsel, Division of Enforcement, Market Abuse Unit, US Securities and Exchange Commission (2015-2019)