Lawrence Billimek and Alan Williams

U.S. SECURITIES AND EXCHANGE COMMISSION

Litigation Release No. 26645 / September 22, 2026

Securities and Exchange Commission v. Lawrence Billimek and Alan Williams, No. 22-cv-10542-JHR (S.D.N.Y. filed Dec. 14, 2022)

SEC Files Proposed Settlement with Respect to Former Financial Services Professional and Associate for Front-Running Scheme

On September 17, 2026, the SEC filed proposed final judgments in the U.S. District Court for the Southern District of New York as to the Commission’s claims against Lawrence Billimek and Alan Williams. If approved by the court, the proposed final judgments would settle the SEC’s previously-filed action alleging that Billimek and Williams engaged in a multi-year front-running scheme that generated approximately $47 million in illegal trading profits.

The SEC’s complaint, filed on December 14, 2022, alleged that, from at least September 2016, Billimek would inform Williams of market-moving trades placed by a major asset management firm prior to their execution. Billimek was employed by the asset management firm at the time. According to the complaint, Williams would trade in the same securities, on the same day, prior to Billimek’s employer or while multiple large orders were being placed by the employer. Williams would close his positions after the price of the security moved as expected. 

Billimek and Williams consented to the entry of the final judgments permanently enjoining them from violating Section 17(a) of the Securities Act of 1933 and Section 10(b) of the Securities Exchange Act of 1934 and Rule 10b-5 thereunder and, as to Billimek, also enjoining him from violating Section 17(j) of the Investment Company Act of 1940 and Rules 17j-1(b)(1) and (3) thereunder. The proposed final judgments, which are subject to court approval, also order disgorgement of $12,684,000 as to Billimek and disgorgement of $34,627,659 and prejudgment interest of $12,027,557.75 as to Williams, all of which are deemed satisfied by the order of forfeiture entered in the parallel criminal case, United States v. Lawrence Billimek and Alan Williams, 22 cr. 675 (PGG) (S.D.N.Y.).

The case originated from the SEC’s Market Abuse Unit’s Analysis and Detection Center, which uses data analysis tools to detect suspicious trading patterns.. The SEC’s litigation was conducted by Terry Miller and supervised by Gregory Kasper of the SEC’s Denver Office. The SEC’s investigation was conducted by Market Abuse Unit staff members David Bennett, Jeffrey Oraker, and John Rymas, and was supervised by Danielle Voorhees and Joseph Sansone, Chief of the Market Abuse Unit.