Financial Disclosure and Accounting Fraud

Served as a Securities and Exchange Commission (SEC) enforcement attorney, federal prosecutor and the first director of the Division of Enforcement for the Public Company Accounting Oversight Board (PCAOB).
Conducts internal investigations on behalf of senior management, audit committees and boards of directors.
Regularly advises clients on SEC financial reporting, disclosure, compliance, and corporate governance requirements.
Claudius offers extensive enforcement experience across a broad range of capital market regulatory and corporate governance matters, including representing corporations, accounting and other professional firms, investment firms and other financial institutions in front of the Department of Justice (DOJ), SEC, PCAOB and other regulatory bodies.
As an SEC enforcement attorney and a federal prosecutor for over a decade, Claudius investigated and prosecuted insider trading, offering fraud, accounting fraud, government contract fraud and bribery matters. Claudius then became the PCAOB’s first enforcement director, leading the team that built the enforcement group from its inception. He oversaw the development of the PCAOB’s policies and procedures for identifying matters for investigation, and he led investigations of U.S.-and foreign-based accounting firms, with many of them also requiring coordinating parallel investigations with the SEC. Claudius’ role also included overseeing the PCAOB’s litigation process. He also played a key role in the PCAOB’s collaboration with its foreign audit regulator counterparts.
Claudius managed a team of more than 60 lawyers, accountants and other professional staff with enforcement jurisdiction over 1,900 registered accounting firms. Annually, he oversaw more than 100 investigations spanning a broad range of audit matters, including:

• Accounting fraud
• Revenue recognition
• Asset impairment
• Illegal acts
• Disclosure violations
• Noncooperation.

Prior to a 14-year tenure at the PCAOB, Claudius served with the Fraud Section of the DOJ’s Criminal Division as a trial attorney, the SEC as an enforcement attorney and the U.S. Attorney’s Office for the Eastern District of Virginia (EDVA) as a federal prosecutor in the Financial Crimes and Public Corruption Unit.

Jennifer S. Leete is a member of the Investigations and Regulatory Enforcement Practice. She is a former Associate Director in the Division of Enforcement at the Securities and Exchange Commission (SEC), where she served for more than 20 years.
Ms. Leete represents public and private companies, financial institutions, auditors, audit committees, boards of directors, executives and board members in connection with sensitive and complex investigations, enforcement and regulatory matters. She also conducts internal investigations on behalf of board committees and companies and advises clients on corporate governance and regulatory compliance issues.
As a Senior Officer and member of the Division of Enforcement’s leadership team, Ms. Leete supervised a broad range of highly complex investigations and enforcement actions, managed a team of approximately 50 attorneys and collaborated closely with the SEC’s regulatory divisions. She regularly coordinated the resolution of matters with other authorities, including the Department of Justice, the Commodity Futures Trading Commission, state securities regulators, international securities regulators and self-regulatory organizations, including the Financial Industry Regulatory Authority and Public Company Accounting Oversight Board.
During her tenure at the SEC, Ms. Leete investigated, supervised and filed enforcement actions involving financial fraud and disclosure violations at public companies, as well as misconduct at major broker-dealers, investment advisers, auditing firms, private funds and self-regulatory organizations. She also led investigations in emerging areas of the securities laws, including issues related to ESG, digital assets and cryptocurrencies, SPACs and Regulation Best Interest, in addition to insider trading, internet and offering frauds, and Ponzi schemes.
Ms. Leete joined the SEC in 1999 as a Staff Attorney in the Division of Enforcement. She became a Branch Chief in 2003 and an Assistant Director in 2010. She is a recipient of the Capital Markets Award, the Chairman’s Award for Excellence and several Division Director Awards. Prior to joining the SEC, Ms. Leete was a litigator in private practice in Washington, D.C.
Ms. Leete is the Managing Editor of the 2023 edition of the Practising Law Institute’s SEC Compliance and Enforcement Answer Book, for which she also contributed three chapters.
Ms. Leete received a B.A. in 1990 from the College of William & Mary and a J.D. in 1993 from the University of Maryland School of Law, where she was the Managing Editor of the Maryland Law Review. After graduation, she served as a law clerk to Hon. Lawrence F. Rodowsky of the Court of Appeals of Maryland.

Jason Flemmons is a Senior Managing Director at Ankura in the Washington, DC office. Jason has over 25 years of experience in forensic accounting, corporate investigations, and technical accounting and auditing matters. He provides a broad range of expert and consulting services involving accounting advisory, auditor liability, fraud examination, dispute resolution, and other services.
Prior to joining Ankura in 2016, Jason was a Senior Managing Director in the Forensic Accounting and Advisory Services practice at FTI Consulting.
Jason is the former Deputy Chief Accountant of the Securities and Exchange Commission’s Division of Enforcement, where he supervised and performed numerous financial and accounting fraud investigations involving SEC registrants and other parties. During his 12 years of service in the Division of Enforcement, Jason advised on a wide variety of technical accounting, auditing, disclosure, and internal control matters. He also performed and managed cash-tracing investigations resulting from violations of the Foreign Corrupt Practices Act, asset misappropriations and Ponzi schemes. Jason co-chaired the Division of Enforcement’s Cross-Border Working Group, which oversaw and coordinated numerous investigations involving issuers and auditors located in foreign jurisdictions. Jason worked closely with both SEC trial counsel and criminal prosecutors during the litigation of high-profile matters.
Before joining the SEC, Jason was a manager in the Financial Advisory Services practice of PricewaterhouseCoopers where he supervised a variety of forensic accounting investigations. He also performed financial statement audits of both publicly traded and privately held companies in a variety of industries located in the US and overseas in PwC’s Audit and Business Advisory Services practice.
From 2015 to 2019, Jason served on the Executive Committee of the AICPA’s Forensic and Valuation Services section. The committee provides guidance and establishes standards for practitioners in the forensic accounting and valuation services industry, including Statement on Standards for Forensic Services No. 1, of which Jason was a principal author. Jason also served on the AICPA’s Forensic and Litigation Services Fraud Task Force from 2012 to 2017. Jason is a frequent speaker at SEC enforcement, accounting and forensic accounting conferences nationally and internationally.

Mark Cave is an Associate Director in the U.S. Securities and Exchange Commission’s Division of Enforcement. He joined the SEC in 2010 as a staff attorney and has served as an Assistant Director and as Senior Counsel to the Director of Enforcement. Mark has led and supervised numerous significant enforcement actions involving public company accounting and disclosure violations, market manipulation, hacking, FCPA violations, SPACs, ICOs, and insider trading. Prior to joining the SEC, Mark was in private practice in New York. He received his J.D. from New York University School of Law and a B.A. from Duke University.

Jonathan R. Tuttle is a partner with Debevoise. He has represented public companies, boards of directors, audit and special committees of boards and individual directors, officers and employees in Securities and Exchange Commission enforcement inquiries, securities class actions, shareholder derivative suits, internal corporate investigations, and a variety of other securities and finance related litigation and regulatory matters. Mr. Tuttle has significant experience investigating accounting issues and representing public companies in connection with restatements of their financial statements, including advising companies with respect to the issues raised by restatements in the areas of disclosure and reporting, SEC enforcement, class and shareholder derivative litigation and relationships with outside auditors.

Mr. Tuttle was an associate at a leading law firm in Washington, D.C. from 1992 to 1995, where he represented primarily broker-dealers, registered persons and other individuals in SEC, National Association of Securities Dealers and New York Stock Exchange enforcement inquiries, securities customer arbitrations and civil litigation. Mr. Tuttle joined Debevoise in 1995. He received his B.A., with honors, from the College of William & Mary in Virginia in 1989, where he majored in English and Economics. He received his J.D., cum laude, from Harvard Law School in 1992. Mr. Tuttle is admitted to practice in Washington, D.C., Virginia and the United States District Courts for the District of Columbia and the Eastern District of Virginia.