Tami Stark
Biography
Overview
Tami Stark's practice focuses on representing companies and individuals facing white collar criminal and regulatory investigations. Having spent over eight years in the Enforcement Division of the U.S. Securities and Exchange Commission, Tami offers clients unique expertise in conducting internal investigations and navigating government inquiries.
Tami combines her extensive experience advising clients on white collar matters with her experience inside of the SEC to obtain quick, efficient and successful outcomes for her clients. Tami has advised clients in matters relating to, among other things: financial and accounting fraud; AI, cybersecurity and ESG disclosures; insider trading; private equity and hedge fund investment adviser conflicts of interest; executive compensation and perks; market manipulation; cryptocurrencies or other digital assets; and the FCPA.
Tami served as Assistant Regional Director in the SEC's Enforcement Division, where she led enforcement efforts alongside other regulators and agencies, including the U.S. Department of Justice, New York Attorney General's Office, FINRA and the Options Regulatory Surveillance Authority. She conducted and supervised investigations concerning: insider trading, financial/accounting fraud, investment adviser and broker dealer violations, best execution, and municipal securities fraud. She also managed the complex process for retaining compliance monitors and fair fund distribution consultants.
Before joining White & Case, Tami practiced at a white collar criminal defense firm where she advised clients in major criminal and regulatory investigations. She managed the Monitorship of a large not-for-profit organization, which had been the subject of fraud investigations by city and state regulators, and the Auditorship of a pharmaceutical company, which had been the subject of an opioid investigation. Tami also clerked for the Honorable Carol B. Amon on the U.S. District Court for the Eastern District of New York.
Experience
Persuaded SEC to Close Investigation Without Action
Represented public telecommunications company through complex accounting fraud investigation
Represented a major rental car company in SEC investigation of pandemic related disclosure failures
Represented a major private equity firm and an acquiree in SEC financial fraud investigation
Represented multiple U.S. listed companies through FINRA and SEC insider trading investigations
Represented former officers of a SPAC through an SEC investigation regarding allegedly false projections in connection with SPAC's business combination
Represented multiple senior executives in FCPA investigations conducted by the DOJ and SEC
Negotiated Favorable Settlement
Represented the Special Committee of the Board of Directors of a China-based U.S. listed company, Cloopen, in SEC investigation of accounting fraud
Represented public company in SEC investigation of executive compensation and related party transaction disclosures
Represented FINTECH company in investigation by multiple states relating to the offer and sale of a cryptocurrency lending product. Negotiated favorable settlement with one state and persuaded other states to close investigations without action
Other Representative Matters
Representing hedge fund executive in SEC and DOJ investigation of AI related fraud
Representing registered investment adviser in connection with SEC investigation of alleged failures to disclose conflicts of interest
Representing U.K.-based U.S. listed company in SEC and DOJ investigation relating to de-SPAC transaction
Representing Canadian-based U.S. listed company and its CEO in connection with SEC and DOJ investigation and litigation relating to potential offering fraud and market manipulation by former investors
Monitorships
Led Monitorship team for large not-for-profit organization whose previous CEO was convicted of kickback scheme in high profile prosecution brought by the New York Attorney General's Office. Reported to multiple New York State and New York City agencies for over four years. During that time, helped the organization: improve Board Governance; install new executive staff leadership with financial, compliance and governance experience; strengthen compliance by drafting new policies and conducting new trainings; enhance financial controls; and streamline and strengthen the financial statement and budget processes.
Spearheaded three-year Auditorship of a pharmaceutical corporation subject to investigation by New York State Attorney General over its opioid marketing practices. Responsible for monitoring company's compliance with agreement with Attorney General resolving investigation, as well as ongoing practices and procedures.
Panelist, "Current Trends in Securities Class Action Litigation", PLUS D&O Symposium, March 1, 2022
Moderator, "The Biden Administration’s National Security Study Memorandum (NSSM): Predictions on the Global Enforcement Aftermath and Evolving Risk Landscape", ACI's International Conference on the FCPA, December 1, 2021
Co-author, "SEC's Action on Recyclability Statements Shows Continued Focus on ESG Related Claims", White & Case LLP, October 2024
Co-author, "DOJ to Evaluate AI Risk Management and Whistleblower Protections in Corporate Compliance Programs", White & Case LLP, October 2024
Co-author, "Time to Review Whistleblower Provisions: SEC Charges Seven Public Companies with Violation of Whistleblower Protection Rule" White & Case LLP, September 2024
Co-author, "FinCEN Issues Final Sweeping AML Requirements for Registered Investment Advisers & ERAs" White & Case LLP, September 2024
Co-author, "DOJ & SEC Bring Enforcement Actions Against Short Sellers, Highlighting Continued Prevalence of Short Selling Against Public Companies" White & Case LLP, September 2024
Co-author, "SEC Continues Focus on Off-Channel Communications" White & Case LLP, August 2024
Co-author, "DOJ Launches New Whistleblower Pilot Program" White & Case LLP, August 2024
Co-author, "Judge Rejects SEC's Aggressive Approach to Cybersecurity Enforcement" White & Case LLP, July 2024
Co-author, "DOJ's Novel Application of Insider Trading to 10b5-1 Plans Leads to Conviction", White & Case LLP, July 2024
Co-author, "Supreme Court rules SEC use of in-house tribunals is unconstitutional in potentially far-reaching decision", White & Case LLP, July 2024
Co-author, "SEC Enforcement Director Outlines His View of Effective Cooperation", White & Case LLP, June 2024
Co-author, "SEC's Corp Fin Director Issues Statement on Cybersecurity Incident Disclosures: Key Take-Aways from White & Case Survey of Cybersecurity Disclosures", White & Case LLP, May 2024
Co-author, "FinCEN and SEC Move Closer to New AML Requirements for Investment Advisers & ERAs", White & Case LLP, May 2024
Co-author, "SEC Warns Individual Actors of Potential Liability for AI-Related Security Risk Disclosure Failures", White & Case LLP, April 2024
Co-author, "'Novel' or Not: the SEC and DOJ's Expansion of Insider Trading to 'Shadow Trading' and 10b5-1 Plans Survive Their Days in Court", White & Case LLP, April 2024
Co-author, "New Settlements Demonstrate the SEC's Ongoing Efforts to Hold Companies Accountable for AI-Washing", White & Case LLP, March 2024
Co-author, "DOJ Doubles Down on Warnings Against AI Misuse", White & Case LLP, March 2024
Co-author, "DOJ Announces Pilot Program to Pay Monetary Rewards to Whistleblowers", White & Case LLP, March 2024
Co-author, "SEC Enforcement Director Emphasizes Current Tools Exist for Combatting Inaccurate Environmental Disclosures", White & Case LLP, March 2024
Co-author, "Recent Regulatory Announcements Confirm Increased Scrutiny of 'AI-Washing'", White & Case LLP, February 2024
Co-author, "The SEC's Settlement with Cloopen Demonstrates the Significant Benefits of Prompt Cooperation", White & Case LLP, February 2024
Co-author, "FinCEN Again Proposes Sweeping AML Requirements for Registered Investment Advisers & ERAs", White & Case LLP, February 2024
Co-author, "How to Avoid Risk of SEC Whistleblower Rule Violations in Connection with Settlement Agreement Confidentiality Provisions", White & Case LLP, January 2024
Co-author, "Navigating New Frontiers in Regulatory Enforcement: the SEC Increases Scrutiny of Artificial Intelligence", White & Case LLP, December 2023
Co-author, "The SEC's Charges Against SolarWinds and Its Chief Information Security Officer Provide Important Cybersecurity Lessons for Public Companies", White & Case LLP, November 2023
Co-author, "SEC Lists Crypto and Information Security Among its 2024 Examination Priorities", White & Case LLP, November 2023
Co-author, "SEC's Focus on Off-Channel Communications Continues", White & Case LLP, October 2023
Co-author, "The SEC Continues to Prove it is the Most Powerful Influencer: How to Avoid Touting Charges", White & Case LLP, May 2023
Co-author, "How to Avoid Risk of SEC Whistleblower Rule Violations in Connection with Employee-related Documents", White & Case LLP, March 2023
Author, "The SEC scored record penalties in fiscal year 2022", Mixed Signals, US M&AFY2022, January 2023
Co-author, "ESG is increasingly critical in US M&A, but greenwashing concerns persist", Mixed Signals, US M&AFY2022, January 2023
Author, "The SEC Bares its Teeth", Reality Check: US M&A H12022, White & Case LLP, August 2022
Co-author, "US Regulators Seek to Prevent the Use of Crypto to Circumvent Russia Sanctions", White & Case LLP April 2022
Co-author, "How to Manage the Risks of SPAC Securities Fraud Actions in 2022", White & Case LLP, March 3, 2022
Co-author, "How Digital Asset Innovators Can Manage the Risks of White Collar Scrutiny in the US", White & Case LLP, February 18, 2022
Co-author, "Time to Revisit Insider Trading Policies: The SEC's Expansion of Insider Trading Enforcement to 'Shadow Trading' Survives Motion to Dismiss", White & Case LLP, February 2, 2022
Co-author, "SEC Enforcement Ramps Up", White & Case LLP, January 31, 2022
Co-author, "SEC Focuses on Potential Misuse of Material Non-Public Information in Stock Trades: Proposed Amendments Regarding Rule 10b5-1 Trading Plans and Company Buybacks", White & Case LLP, December 22, 2021
Co-author, "Deputy Attorney General Announces Reinvigorated Focus on Corporate Crime", White & Case LLP, November 10, 2021
Co-author, "The Evolution and Current Approach to Corporate Cooperation in US Enforcement Investigations", Global Investigations Review: Americas Investigations Review, September 2021
Co-author, "SEC Extends the Misappropriation Theory of Insider Trading Beyond Targets of Acquisitions to Companies 'Economically Linked' to Such Targets", White & Case LLP, September 9, 2021
Co-author, "Time to Revisit Risk Factors in Periodic Reports", White & Case LLP, August 5, 2021
Co-author, "DOJ Global Corruption Efforts Beyond the FCPA," GIR's Americas Investigations Review 2021
Co-author, "Liu v. SEC: Supreme Court Affirms SEC's Disgorgement Authority But Imposes Limitations," White & Case LLP, June 24, 2020
Co-author, "Mitigating Risk of Fraud During the COVID-19 Crisis," White & Case LLP, April 1, 2020
Co-author, "Congress Passes $2.2 Trillion COVID-19 Stimulus Bill," White & Case LLP, March 27, 2020
Co-author, "US v. Hoskins: FCPA Guilty Verdict Overturned as Court Gives Definition to the Term 'Agent,'" White & Case LLP, March 3, 2020
Co-author, "United States v. Hoskins & Scoville v. SEC: DOJ & SEC extend their extraterritorial reach for FCPA & securities fraud charge," White & Case LLP, November 18, 2019
SEC Ellen B. Ross Award for exemplary commitment, enthusiasm and performance
