Speech by SEC Staff: Remarks Before the New York City Bar: My First 100 Days as Director of Enforcement

"The addition of the specialized enforcement unit Mr. Khuzami describes is a very important development. But, the SEC and DOJ have also stepped up enforcement in other ways, including prosecuting more individuals, seeking massive fines and employing aggressive legal theories. Consequently, companies lacking adequate internal controls and due diligence procedures swim in increasingly perilous waters." -- David F. Axelrod

David F. Axelrod, Director, Forensic & Dispute Services
FCPA Leader, North Central Region
Deloitte Financial Advisory Services LLP

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Source: U.S. Securities and Exchange Commission Website

By: Robert Khuzami
Director, Division of Enforcement
U.S. Securities and Exchange Commission

New York, New York
August 5, 2009

I. Introduction

Thank you, Pat, for that kind introduction. It's great to be back in New York. And I am grateful to the New York City Bar for providing me with this opportunity to talk about the Enforcement Division. There is lots to talk about.

As I was thinking about this speech, a colleague mentioned that I had been with the Commission approximately 100 days. Aside from making me wonder why my colleagues are counting, it caused me to pause and reflect — how did my 100-day accomplishments compare with those of others? That often over-weighted yardstick of accomplishment — did I measure up?

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