SEC Obtains Final Judgment Against Former Dewey & Leboeuf, LLP Executive

Litigation Release No. 25549 / October 4, 2022

Accounting and Auditing Enforcement No. 4352 / October 4, 2022

Securities and Exchange Commission v. Steven H. Davis, et. al, Civil Action No. 14-cv-01528 (S.D.N.Y.)

The Securities and Exchange Commission announced today that on October 3, 2022, the Honorable Valerie E. Caproni of the United States District Court for the Southern District of New York entered a final judgment against former Dewey & LeBoeuf, LLP executive Joel Sanders, Esq., in an SEC enforcement action arising from his role at the now-defunct international law firm's fraudulent $150 million bond offering.

In 2014, the SEC filed suit against Sanders and others in federal district court in Manhattan. The SEC's complaint alleged that in 2008 and 2009, Sanders, then the chief financial officer of Dewey & LeBoeuf, in conjunction with other employees, hatched a scheme, and directed his staff, to materially falsify the firm's financial statements in order to meet lender covenants. In March 2010, Dewey & LeBoeuf conducted a $150 million private placement of bonds. According to the SEC's complaint, Sanders defrauded the firm's investors in that offering by, among other things, providing a private placement memorandum to investors that incorporated the fraudulent financial statements.

Sanders consented to the entry of a final judgment ordering him to pay disgorgement of $86,250.00 and prejudgment interest thereon of $8,779.71. The final judgment to which Sanders consented also contains the previously imposed injunctive relief, which permanently enjoins him from future violations of Section 17(a) of the Securities Act of 1933 and Section 10(b) of the Exchange Act of 1934, and Rule 10b-5 thereunder, and prohibits him from acting as an officer or director of a public company. Sanders was also suspended from appearing or practicing before the Commission as an attorney. The settlement resolves the SEC's case against Sanders, and concludes this litigation.

The SEC staff in the New York Regional Office responsible for the investigation and the litigation includes William Finkel, Joseph P. Ceglio, Christopher C. Mele, Lee A. Greenwood; and Thomas P. Smith Jr., who has also supervised the case.

For further information, see Press Release 2014-45 (March 6, 2014), Litigation Release No. 23443, Litigation Release No. 23475, and Litigation Release No. 24119.