Accounting Fraud & SEC Investigations: Recent Enforcement Initiatives and Compliance Issues

John Rademacher is a principal in CRA’s Forensic Services Practice, serving as a trusted advisor during times of crisis and helping organizations demonstrate their commitment to integrity by maintaining effective compliance programs and quickly uncovering truth when responding to allegations of misconduct. He delivers value by deploying cross-functional teams of experienced professionals who get to truth more quickly than under traditional methods. He has significant experience advising corporate clients and their external counsel in matters related to ethics and compliance programs, forensic investigations, regulatory enforcement, third-party risk management, and anti-bribery and corruption. He has demonstrated experience conducting investigations in over 20 countries and has successfully built compliance programs for clients in a variety of industries. He frequently works with cross-functional teams consisting of in-house and external counsel, forensic technology, corporate intelligence, data-analytics, and deep industry expertise to deliver quality service.

He assists Boards of Directors, General Counsel, and Chief Compliance Officers in developing and sustaining effective ethics and compliance programs for large multinational corporations and high-growth companies. This has regularly included evaluating compliance program frameworks and delivery models, advising on the design and implementation of compliance program elements, developing compliance strategies, and supporting clients in reporting to regulators in response to enforcement actions. These transformations often focus on establishing governance structures that drive ethical conduct; simplifying policies and procedures; developing effective risk assessments; evolving training and communications to align with adult-learning; establishing risk-based auditing and monitoring strategies; and revamping hotline, investigations, and disciplinary mechanisms to meet regulator expectations.

Rebecca is an experienced litigator focused on shareholder enforcement, government and internal investigations, and white collar defense. Rebecca served as Senior Counsel in the SEC’s Division of Enforcement for nearly 10 years. At the SEC, she ran all aspects of her investigations, and she frequently conducted investigations in parallel with the DOJ and other civil and criminal agencies. The SEC recognized Rebecca for her efforts with an Annual Enforcement Director’s Award for excellence in investigative work, as well as the inaugural Performance Incentive Bonus award for demonstrating an “extraordinary and rare level of performance that significantly surpasses the requirements of the job.” Rebecca brings clients a current, insider’s perspective on how to best guide them through the reality of today’s SEC investigations.

Chris Ahart is a Senior Counsel in the Enforcement Division of the Securities and Exchange Commission’s Fort Worth Regional Office. Since joining the SEC in 2013, Chris has investigated a wide variety of cases but generally specializes in complex financial and accounting frauds, including the Commission’s first case against auditors for improperly “predating” work papers. Before his tenure at the SEC, Chris worked in private practice for over ten years at Akin Gump Strauss Hauer & Feld and Vinson & Elkins. He is also a former CPA and alumnus of Arthur Andersen. Chris earned his Bachelor of Business Administration, Master in Professional Accounting, and Juris Doctorate degrees from the University of Texas.