Adam S. Aderton

Adam Aderton, a former Co-Chief of the SEC’s Enforcement Asset Management Unit, is a Partner in Simpson Thacher’s Litigation Practice. Based in the Firm’s Washington, D.C. office, Adam focuses on regulatory and enforcement matters, with a particular emphasis on the asset management industry. He advises on complex regulatory inquiries and litigation matters involving private equity funds, venture capital funds, hedge funds, BDCs, mutual funds and ETFs, as well as separately managed accounts. He also provides asset managers with practical ongoing compliance advice.

A thought leader in the space, Adam regularly speaks on asset management enforcement issues to leading industry groups, including the Investment Adviser Association, the Investment Company Institute and the Institutional Investor Legal Forum, among others.

Adam spent more than 14 years at the SEC’s Division of Enforcement, including serving from 2019-2022 as the Co-Chief of the Enforcement Asset Management Unit. In that role, he directed the SEC’s investigative teams responsible for investigations and enforcement matters for asset managers across the country. Adam also led Enforcement’s coordination with the Division of Examinations and advised on significant rulemakings involving the asset management industry. He was recently named among Securities Docket’s “Enforcement Elite.”

Notable experience prior to joining Simpson Thacher includes advising:

• Various registered investment advisers in multiple SEC investigations involving: the calculation of private equity fund management fees; the pay-to-play rules; the marketing rule; the SEC whistleblower rules; material non-public information controls; block trading practices; and off-channel communications. Many of the investigations were terminated with no action against the client.
• Multiple internal investigations, involving: allegations of misrepresentation of investment strategy against a registered investment adviser; allegations of failure to enforce information barriers against a registered investment adviser; and SEC filings by a registered investment adviser.
• A trader in an SEC investigation involving collateralized mortgage obligations. The investigation was terminated with no action against the client.
• An investment adviser and its principal in an SEC investigation involving alleged undisclosed conflicts of interest. The investigation was terminated with no action against the client.
• An information services provider in an SEC investigation involving marketing materials.
• A software company CEO in an SEC investigation involving crypto asset registration. The investigation was terminated with no action against the client.
• Executives in an SEC investigation involving off-channel communications.

Adam received his J.D. from University of Virginia School of Law in 2004, where he was a member of the Order of the Coif and Editor of the Virginia Law Review. He received his B.A. from Truman State University in 2001. He is admitted to practice in the District of Columbia and Maryland. Adam clerked for the Hon. J. Frederick Motz of the U.S. District Court for the District of Maryland from 2004-2005.