Peter I. Altman

Partner

Areas of Focus

Peter I. Altman

Partner

paltman@akingump.com

Areas of Focus

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Biography
  • Represents prominent investment management firms, public & private companies and individuals in highly sensitive white collar & government investigations, regulatory examinations, investment fund and securities litigation, and internal investigations.
  • Significant experience in matters before the SEC, CFTC and DOJ, focusing on matters relating to the investment management industry.
  • Serves as a leader in Akin’s digital assets, cryptocurrency & blockchain practice, having represented senior executives, traders and companies in some of the largest and most high-profile government investigations of cryptocurrency exchanges and trading platforms.
  • Served in the SEC’s Division of Enforcement in Los Angeles and as a member of the division’s Market Abuse Unit.

Peter is a highly regarded litigator and a leading name of the white collar bar. He is a go-to lawyer in the investment funds space, assisting investment management clients with respect to regulatory compliance with federal securities and commodities laws.

In the wake of the U.S. Securities and Exchange Commission (SEC)’s heightened focus on investment funds and managers, Peter has assisted numerous investment management clients on meeting new regulatory requirements, implementing compliance programs and advising on SEC enforcement investigations, all while helping to mitigate risk. Peter also regularly handles matters in California state and federal courts for investment funds and other clients. 

With a cutting-edge practice, Peter is also a leader in the firm’s digital assets, cryptocurrency & blockchain group. He represents senior executives, traders and other companies in complex, multilayered investigations, including in high-profile government investigations of cryptocurrency exchanges and trading platforms, decentralized finance (DeFi) and other digital assets such as smart contracts and non-fungible tokens (NFTs).

Peter stands out as among a handful of lawyers with extensive experience handling U.S. Commodity Futures Trading Commission (CFTC) investigations, which is notable because the CFTC has jurisdiction over key aspects of the crypto ecosystem.

Prior to joining Akin, Peter served in the Division of Enforcement of the SEC’s Los Angeles Regional Office. As a result, Peter brings to bear significant public & private sector experience when representing clients in government investigations and litigation, and in providing risk and compliance counseling to investment advisory firms.

Efficient, responsive and careful, Peter understands how government agencies identify, investigate, evaluate and present cases for enforcement action. Peter’s experience serving at the SEC provides him with a deep familiarity of the federal securities laws and the processes of the SEC.

Peter routinely provides advice in investigations and enforcement proceedings involving issues such as alleged insider trading and other forms of market abuse, and disclosure-related and regulatory compliance issues. He also advises investment advisers on day-to-day risk management issues related to topics including securities trading, compliance with the Investment Advisers Act, electronic communication usage and the use of alternative data and web scraping in the investment research process.

Further, Peter is active on several Akin leadership committees, including as a member of the firm’s Partnership Admissions Committee and as chair of the Los Angeles Office Hiring Committee.

Peter is a frequent contributor to thought leadership covering the issues that are top of mind for his clients. He also co-authored the SEC Enforcement—Legal Considerations chapter in Federal Securities Exchange Act of 1934, a comprehensive treatise on the Securities Exchange Act of 1934 published by Matthew Bender.

Representative Work
  • Represented a co-founder of a leading cryptocurrency derivatives trading platform in a first-of-its-kind and closely-watched criminal case brought by the Southern District of New York (SDNY) alleging violations of the Bank Secrecy Act (BSA), as well as a related CFTC civil enforcement arising from alleged failure to register with the commission. Also handles the defense of numerous civil lawsuits for the client.
  • Led the representation of a high-frequency cryptocurrency trading firm in a government investigation of a cryptocurrency exchange. The CFTC sued the exchange and no charges were filed against the client.
  • Represented a leading high-frequency trading firm in connection with a U.S. Department of Justice (DOJ) investigation related to the firm’s trading of cryptocurrency derivatives on offshore exchanges. Conducted a comprehensive review of the client’s cryptocurrency trading business, which involved the review of thousands of documents and well over a dozen witness interviews in the United States and Asia. Presented the findings from our internal investigation to the DOJ. To date, no action has been taken against the client. This matter involves complex questions regarding the jurisdiction of the U.S. authorities over offshore crypto trading, which is a cutting-edge and rapidly developing area of the law.
  • Led the representation of an SEC Electronic Data Gathering, Analysis and Retrieval system (EDGAR) filing agent in connection with a DOJ and SEC investigation regarding a cybersecurity breach of the client’s computer systems and resulting alleged insider trading based on material nonpublic information (MNPI) associated with the client’s customers. The alleged hackers and traders were indicted, sued and ultimately sentenced. No charges were filed against the client, which was identified as a principal victim of the hack, and the client was not named in the public action taken by the government. The defendant was sentenced to nine years in prison and the court is considering the magnitude of an order of restitution to the client.
  • Led the representation of an SEC-registered investment adviser that specializes in private credit transactions. The client was identified as a principal victim of fraudulent conduct by a borrower. Through a carefully executed strategy of engagement and cooperation with the SEC and DOJ, Akin successfully kept the client’s name out of the government’s charging papers. Our team also worked on a restructuring of the borrower’s company that led to a successful credit bid purchase of the collateral pledged by the borrower in the loan documentation.
  • On behalf of a global asset manager, led an internal investigation relating to allegations by an employee of sexual harassment and hostile workplace conditions.
  • Co-led the representation of an SEC-registered investment adviser, in connection with an SEC investigation regarding alleged failure to disclose certain conflicts of interest related to the firm’s sponsorships and investments in several special purpose acquisition companies (SPACs). After making several presentations to the SEC, the Akin team reached a favorable settlement that was limited to negligence-based violations of the Investment Advisers Act.
  • Represented an SEC-registered investment adviser, in connection with charges by the SEC for failing to comply with the Custody Rule, an SEC rule relating to the preparation and delivery of audited financial statements for private funds. The SEC announced the settlement as part of a sweep involving several other investment advisers. Akin obtained a favorable settlement and the lowest civil monetary penalty amongst the group of announced settling parties.
  • Led the representation one of the founders of a digital asset DeFi organization, in connection with various charges from the CFTC against the company, including failing to properly register as a swap execution facility, and failing to meet BSA requirements. Advised and successfully settled the matter for the client, who was not mentioned in the public documents. The client also received a closing letter from the CFTC’s Division of Enforcement, a rare achievement in CFTC investigations.
  • Co-led the representation of a former controller of a construction company in connection with an investigation into the company by the SEC, which resulted in a settlement with the company and multiple former executives, as well as a litigated action against an additional executive. No charges were filed against our client.
  • Representing a registered investment adviser that engaged in an activist investment strategy in connection with an investigation by the SEC’s Division of Enforcement concerning potential conflicts of interest regarding the adviser’s consulting relationships with third-party funds.
  • Leading the representation of an SEC-registered investment adviser that engages in an activist investment strategy in connection with an examination by the SEC that resulted in a deficiency letter.
  • Co-leading the representation of a CFTC-registered introducing broker in connection with an investigation relating to off-channel communications practices at the firm.
  • Defended a major hedge fund advisor in an investigation by the SEC and a related criminal investigation in SDNY concerning insider trading allegations. No charges were filed against the client and the client was not named in public action taken by the government against a former employee of the advisor.
  • Represented a former executive at a well-known virtual currency trading platform in a CFTC investigation regarding virtual currency trading practices on that platform. No charges were filed against the client and the client was not named in public action taken by the government against its former employer.
  • Represented additional clients in cryptocurrency-related investigations and litigations related to crypto products, regulatory matters and trading practices.
  • In a securities class action alleging control-person liability against a global investment firm, served as architect of the defense strategy and oversaw the execution of all aspects of litigation, including court arguments, depositions, briefings and negotiations. Achieved a huge victory, securing a highly favorable settlement funded wholly by insurance money.
  • Defended an individual in an insider trading investigation by the SEC, and secured the first-ever deferred prosecution agreement with the SEC in such a matter.
  • Defended a large multinational investment adviser in an investigation by the SEC into possible violations of Rule 105 of Regulation M, the SEC regulation to deter manipulative shorting related to public stock offerings, and obtained a closing letter from the Division of Enforcement within 90 days of the initial document request.

Education
  • J.D., Brooklyn Law School, cum laude, 2005

  • B.A., University of Michigan, with honors, 2001

Clerkships
  • U.S.D.C., Southern District of New York

Bar Admissions
  • California

  • New Jersey

  • New York

Recognitions
  • Daily Journal, Top White Collar Lawyers, 2021 and 2023.
  • SEC Enforcement Director Award, for distinction in investigating enforcement matters.
  • Pro Bono Counsel of the Year for Akin Gump’s New York Office.
Speeches and Publications
  • Co-author, Chapter 9: SEC Enforcement—Legal Considerations, Federal Securities Exchange Act of 1934, Matthew Bender.
  • Panelist, “Financial Firms in the SEC’s Crosshairs—Key Developments for Asset Managers, Broker-Dealers, Private Funds and Hedge Funds,” Securities Enforcement Forum West, May 23, 2023.
  • Panelist, “Electronic Communications Sweep: How Large and Small Investment Advisers Can Respond,” DFW Financial Services Counsel Roundtable, Dallas, February 23, 2023.
  • Panelist, “Moving On-chain: Unwinding the Complexity of Crypto,” AICPA’s Forensic & Valuation Services Conference, Nov 14, 2022.
  • Panelist, “Crypto, Digital Assets and Cyber Priorities,” Los Angeles County Bar Association’s 54th Annual Securities Regulation Seminar, October 21, 2022.
  • Panelist, “Cryptocurrency Regulation, Enforcement and Litigation,” Securities Enforcement Forum West 2022, May 12, 2022.
  • Moderator, “Financial Firm Spotlight – Enforcement and Regulatory Developments for Asset Managers, Broker-Dealers, Hedge Funds and More,” Securities Enforcement West 2021, May 13, 2021.
  • Moderator, “What’s Next on the Regulatory and Enforcement Agenda,” Managed Funds Association West 2021, April 7, 2021.
  • Co-panelist, “Navigating the Regulatory Intersection of Data Procurement, Web Scraping, MNPI and Insider Trading Compliance,” MFA DATA, September 16, 2020.
  • Co-panelist, “Material Non-Public Information During the COVID-19 Pandemic: Insider Trading Risks to Avoid,” Akin Webinar, May 14, 2020.
  • Co-panelist, “The SEC’s Focus on Cybersecurity – Disclosure, Enforcement and Key Guidance for 2020,” Securities Enforcement West, May 12, 2020.
  • Moderator, “What’s Next on the Regulatory and Enforcement Agenda,” Managed Funds Association West, February 25, 2020.
  • Co-panelist, “Financial Firm Spotlight – Enforcement and Regulatory Developments for Asset Managers, Broker-Dealers, Hedge Funds and More,” Securities Enforcement West, May 9, 2019.
  • Co-panelist, “SEC Examinations: Perspectives from CCOs Who Went Through Exams During the Past Year – The Best 45 Minutes You Can Spend Preparing For Your Own Exam,” Akin Investment Funds Symposium, April 30, 2019.
  • Co-panelist, “What’s Next on the Regulatory and Enforcement Agenda,” Managed Funds Association West, February 28, 2019.
  • Co-panelist, “What Should Crypto Funds Expect From The SEC Going Forward?,” Securities Docket Webcasts, December 3, 2018.
  • Co-panelist, “CCO Liability: How to Protect Yourself,” Fall 2018 ACA Group Compliance Conference, October 4, 2018.
  • Co-panelist, “Annual Update on Regulatory Developments and Enforcements: U.S. and U.K.,” Akin Annual New York Private Investment Funds Conference, September 27, 2018.
  • Co-panelist, “Financial Firm Spotlight—Enforcement and Regulatory Developments for Asset Managers, Broker-Dealers, Hedge Funds and More,” Securities Enforcement Forum West, May 10, 2018.
  • Moderator, “Managing #MeToo Every Day—Mitigating and Protecting Against the Significant Risks of Workplace Misbehavior,” Akin Investment Funds Symposium, May 3, 2018.
  • Co-panelist, “Today’s Hottest Compliance Issues—Straight Talk So You Don’t Get Burned,” IA Compliance: The Full 360° View West, November 2, 2017.
  • Co-panelist, “Using Data Scraping in the Investment Research Process,” Fall 2017 ACA Group Conference, October 25, 2017.
  • Moderator, “Compliance and Enforcement Priorities for the SEC in the Trump Administration,” Akin and FTI Consulting’s Investment Funds Symposium, June 8, 2017.

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