Tami Stark

Partner, New York

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, navigating government inquiries, and serving as a monitor.

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 or accounting fraud; cybersecurity breaches; SPACs; cryptocurrencies or other digital assets; ESG; market manipulation schemes; securities registration; private equity and hedge fund investment adviser conflicts of interest; executive compensation or perks; insider trading; 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 recommended the selection of, and managed, compliance monitors and fair fund distribution consultants.

Before joining White & Case, Tami practiced at a boutique 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.

Tami currently serves on the New York City Bar's Securities Litigation Committee.

Bars and Courts
New York State Bar
US District Court for the Eastern District of New York
US District Court for the Southern District of New York
Education
JD
Fordham University School of Law
BA
James Madison University
Languages
English

Experience

Criminal/Regulatory Matters

Representing the Special Committee of the Board of Directors of a China-based U.S. listed company in connection with an SEC investigation of accounting fraud.

Representing U.K.-based U.S. listed company in SEC investigation relating to de-SPAC transaction.

Represented FINTECH company in state regulatory investigation of offer and sale of cryptocurrency lending product. No charges were brought.

Representing former officers of a SPAC in connection with an SEC investigation of allegedly false projections in connection with SPAC's business combination.

Represented public company in connection with SEC investigation of executive compensation and related party transaction disclosures. Negotiated favorable settlement with SEC.

Representing SPAC in connection with SEC investigation of potential insider trading ahead of announcement of business combination.

Representing CEO of Canadian-based U.S. listed company in connection with SEC investigation and litigation relating to potential offering fraud and market manipulation by former investors.

Represented a major rental car company in connection with an SEC investigation of pandemic related disclosure failures. The SEC sent a letter stating they were closing the investigation.

Represented a cryptocurrency exchange and issuer in connection with an SEC investigation. No charges have been brought against the company.

Represented officers of a SPAC in connection with an SEC investigation of allegedly false projections disclosed during the SPAC's business combination with a lidar company. No charges have been brought against the officers.

Represented an energy technology company in an insider trading investigation conducted by the SEC. No charges were brought against the company.

Represented a major private equity firm and an acquiree in connection with an SEC financial fraud investigation. Convinced the SEC to close the investigation without a document production or interviewing witnesses.

Represented the Special Committee of the Board of Directors of a public company in connection with an internal investigation of related party transactions.

Represented the CEO of an investment management data analytics company in an investment adviser conflicts of interest investigation conducted by the SEC. No charges have been brought against the client.

Represented the Chief Executive Officer of a major institutional hedge fund manager in connection with an investment adviser fraud investigation by the SEC. No charges were brought against the client.

Represented Chief Financial Officer of an Asia Pacific subsidiary of a large marketing company in connection with an FCPA investigation conducted by the DOJ and SEC. No criminal or civil charges were brought against the client.

Represented the Global Chief Compliance Officer of one of the world's largest business applications companies in connection with an FCPA investigation conducted by the DOJ and the SEC. No criminal or civil charges were brought against the client.

Represented CEO of Asia/Pacific affiliate of a multinational wire and cable solutions corporation in an FCPA investigation by DOJ and the SEC. No criminal or civil charges were brought against the client.

Represented Controller of public company in parallel SEC/DOJ investigations of financial/accounting fraud at the company. Although the company, its CFO and other employees were charged by the SEC and/or DOJ, no criminal or civil charges were brought against client.

Represented Head of Risk of global bank in SEC investigation of money laundering. The client was not charged.

Represented CFO of oil and gas company in parallel criminal and SEC insider trading investigations. No charges were brought against the client.

Represented the Chief Accounting Officer of a publicly traded Real Estate Investment Trust in an SEC investigation of conflicts of interest. The client and the REIT were not charged.

Represented over 40 employees of one of the nation's leading drugstore chains in a grand jury investigation of pseudoephedrine sales practices. None of the employees were charged.

Represented over 10 employees of a freight forwarding company in a defense contract fraud investigation by the Department of Defense and DOJ. None of the employees were charged.

 

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, Tami 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.

Speaking Engagements

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

Publications

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

Awards and Recognition

SEC Ellen B. Ross Award for exemplary commitment, enthusiasm and performance, 2003