Developments in SEC Rulemaking for Cybersecurity, Climate, Private Funds and More

Kristin Snyder is a litigation partner and member of the firm’s White Collar & Regulatory Defense Group. Her practice focuses on securities-related regulatory and enforcement matters, particularly for private investment firms and other asset managers.

Prior to her role at Debevoise, Ms. Snyder served at the U.S. Securities & Exchange Commission (SEC) for 18 years, most recently serving as the Deputy Director of the Division of Examinations resident in its San Francisco Regional Office. In her role, she spearheaded the development of examination priorities for the national and international examination programs covering a spectrum of SEC registrants including investment advisers, investment companies, and broker-dealers.

At the Commission, she also served as National Associate Director of the Investment Adviser/Investment Company (IAIC) Examination Program, and as the San Francisco Regional Office’s Associate Director for Examinations. In these roles and her Deputy Director role, she oversaw more than 1,000 employees in the Division of Examinations, directed the SEC’s Private Funds Unit, a specialized group within the exam program that has conducted hundreds of examinations of many of the largest and most complex private funds managers in the world, and managed referrals of examination findings from the Division of Examinations to the Division of Enforcement. She also led the SEC’s National Examination Program Office for the IAIC Examination Program, which develops priorities and initiatives covering investment advisers, including private fund managers, and investment companies.

Before her position at the Division of Examinations, Ms. Snyder served for eight years in the SEC’s Division of Enforcement as a branch chief and as senior counsel in the SEC’s San Francisco office, and prior to that was a litigation associate at two major law firms.

Ms. Snyder received her J.D. with honors from the University of California, Hastings College of the Law in 1996 and her B.A. from the University of California, Davis in 1992.

Lauren Cook Jackson is counsel in the Washington D.C. office of Gibson, Dunn & Crutcher. She practices in the firm’s Financial Institutions, Securities Regulation and Corporate Governance, Securities Enforcement and Investment Funds practice groups.

Ms. Jackson’s practice focuses on securities regulatory compliance and enforcement matters. She serves as regulatory compliance counsel to retail and institutional broker-dealers and investment advisers. She has also represented global financial institutions, public companies, broker-dealers, investment advisers, private fund issuers, swap dealers, and commercial commodities traders as well as other regulated entities and professionals in responding to examinations, investigations, and enforcement proceedings brought by securities regulators and self-regulatory organizations including: the SEC, CFTC, FINRA, NYSE, DOJ, OCC, CBOE, CME, NFA, NASAA task force groups, and state securities divisions and attorneys general.

Ms. Jackson regularly assists clients in conducting internal investigations into potential violations of state and federal securities laws and in identifying steps necessary to obtain compliance with such regulations, as well as self-reporting to securities regulators when required. She similarly has extensive experience designing and advising on the execution of large-scale remediation programs that balance the concerns and priorities of a firm’s internal constituents, mitigate potential follow-on litigation risk, and fulfill the requirements of relevant regulatory undertakings.

Ms. Jackson graduated from the University of North Carolina at Chapel Hill in 2000 and received her law degree magna cum laude from the University of Richmond School of Law in 2008. She is admitted to practice in the District of Columbia and North Carolina.

Britt Whitesell Biles is a trial lawyer and a partner in the Business Litigation Group. Resident in the firm’s Washington, D.C. office, Britt has extensive experience at the highest levels of the federal government, having served in senior legal roles at the U.S. Securities and Exchange Commission (SEC), the White House, and the U.S. Small Business Administration (SBA). She has nearly two decades of experience representing and advising clients in high-stakes government investigations and bet-the-company litigation.
Most recently, Britt served as the General Counsel of the SBA. She was appointed in 2020 to manage the immense and unprecedented legal needs that arose from the SBA’s role as a lead agency in the federal government’s economic response to COVID-19; the Agency was under intense pressure to implement and administer trillion-dollar loan and grant programs established by the CARES Act and faced unparalleled levels of scrutiny from Congress, the media, and the public. As the SBA’s chief legal officer and third-highest-ranking official, Britt led the SBA’s legal function, managing 140 lawyers and staff across the country.
Britt was the principal legal advisor to the Administrator on the CARES Act and related legislation. She supervised the drafting of regulations and guidance that implemented the Paycheck Protection Program and designed key aspects of the loan review and forgiveness process. She worked closely with senior officials across the federal government to establish data-sharing and cooperation agreements to facilitate the investigation and prosecution of fraud and abuse in the COVID-19 loan and grant programs. Britt oversaw the litigation of cases arising under the CARES Act and devised the SBA’s strategy for responding to oversight, audits, and inquiries. She regularly counseled senior Agency officials in connection with Congressional testimony and briefings, including before the House Committee on Oversight and Reform, the House and Senate Small Business Committees, the House Financial Services Committee, and the House Select Subcommittee on the Coronavirus Crisis. In addition to acting as a legal advisor, Britt performed a crisis management role, advising the SBA on its communications strategy and engagement with external stakeholders. Britt, along with her staff in the Office of General Counsel, received the 2020 Administrator’s Award for Outstanding Achievement.
Before she was appointed General Counsel of the SBA, Britt served as a Special Assistant to the President and Associate White House Counsel. During her tenure at the White House, she provided legal advice on financial regulation and reform, consumer protection, privacy, transportation, and congressional oversight matters. She also was the White House’s legal liaison to the Departments of Treasury, Transportation, and Housing and Urban Development, as well as independent financial services and consumer protection agencies, including the SEC, the Federal Trade Commission (FTC), and the Consumer Financial Protection Bureau.
Britt also recently held a senior enforcement position at the SEC. As Assistant Chief Litigation Counsel, she investigated and litigated securities matters involving insider trading, cybersecurity, accounting and disclosure fraud, registered and unregistered securities offerings, market abuses, the Foreign Corrupt Practices Act, broker-dealers, investment advisors, and other regulated entities. Her cases involved millions of dollars in civil monetary penalties and disgorgement. She routinely worked with the Federal Bureau of Investigation, the Department of Justice (DOJ), and U.S. Attorneys’ Offices on parallel criminal proceedings. Britt also worked with international authorities, handling significant cross-border enforcement actions involving China, Macau, India, and Eastern Europe.
During her time at the SEC, Britt investigated and litigated many of the Commission’s most significant cases. In 2017, she received the Chairman’s Award for Excellence for leading the litigation in SEC v. Hong, a ground-breaking case in which Chinese nationals were charged with insider trading in connection with a cyber-attack on two New York law firms. The case received international attention because it demonstrated the reach of the SEC’s enforcement program as the SEC recovered illegal trading profits from foreign defendants who lived abroad and carried out their illegal scheme without entering the United States. Britt also twice received the Division of Enforcement Director’s Award for making outstanding contributions to the enforcement of the federal securities laws — in 2015, for her work on an $80-million-variable-annuity-fraud case, and again in 2016, for her work on a conflict-of-interest case against one of the world’s largest asset managers and its chief compliance officer.
In addition to serving in senior legal roles in the federal government, Britt was a partner at a global law firm and a Washington, D.C. litigation boutique. She represented high-profile individuals and public and private companies in the financial services, healthcare, pharmaceutical, defense, communications, government contracting, technology, manufacturing, and entertainment industries. She defended clients in investigations and enforcement matters by Congress, the DOJ, the SEC, the FTC, the Federal Deposit Insurance Corporation, and various state attorneys general. She also represented clients in commercial litigation, including securities, contract, cybersecurity, data privacy, defamation, consumer protection, unfair competition, professional liability, environmental, and product liability cases. An experienced trial lawyer, Britt litigated in state and federal courts nationwide. She presented cases to arbitrators and mediators. Britt also was a lecturing fellow at Duke University School of Law, teaching a course on electronic discovery.
Britt began her law career as a federal appellate clerk for the Honorable Julia Smith Gibbons on the U.S. Court of Appeals for the Sixth Circuit, after graduating magna cum laude from Duke University School of Law and being elected to the Order of the Coif.

Luke Tenery, a Partner with StoneTurn, brings nearly 20 years of experience helping leading organizations mitigate complex cybersecurity, data privacy and data protection risks. He applies extensive expertise in cyber investigations, threat intelligence, incident response, and information risk management to assist clients across the threat and risk continuum—from prevention to detection, mitigation through to remediation and transformation. Luke specializes in situational corporate cyber risks. He helps organizations across a range of industries align robust information security risk management with high- impact initiatives including remediation, M&A due diligence and integration, cyber cost analyses, digital transformation, and Secure Operations Center (SOC) and threat intelligence program development. Luke also assists public companies and their Boards in remediating the long-standing control issues that lead to cyber incidents.

Prior to joining StoneTurn, Luke founded the global cyber practice and led the cyber response, investigations, and intelligence practice of an international consulting firm, handling a range of active and emergent cybersecurity threats. Earlier in his career, Luke rose to Deputy Cyber Practice Leader over a 15-year tenure with a global risk management and investigations firm.

Luke is a certified chief information security officer (C/CISO). He has performed interim technology and information security leadership functions for his clients. Luke has also advised on cyber issues at the intersection of risk and compliance, as well as those related to financial fraud and data integrity He is a thought leader and frequent author and speaker on topics including incident response, security data analytics, incident remediation, and cybersecurity compliance in the context of payment card industry (PCI) and CFIUS compliance, among other regulatory enforcement issues.