Prior to joining Skadden, Ms. Bandy served for 17 years at the SEC’s Enforcement Division, where she supervised, investigated and brought actions covering the entire breadth of the SEC’s enforcement authority. She held a number of leadership roles, including most recently serving as an associate director in the division’s Washington, D.C. headquarters, where she supervised a large staff of attorneys, market specialists and supervisors and a vast range of enforcement matters.
During her time at the SEC, Ms. Bandy oversaw some of the most impactful, high-profile enforcement actions against public companies. She is a recognized leader in the financial fraud, accounting and issuer disclosure area and is well positioned to advise public companies, audit or special committees and financial institutions on internal investigations that lead to complex, high-stakes resolutions and litigations, as well as counsel on a comprehensive range of compliance, regulatory and due diligence matters.
While at the SEC, Ms. Bandy worked on hundreds of investigations involving all areas of enforcement authority, including financial reporting and accounting; auditor misconduct; mergers and acquisitions reporting; cyber; offering and registration violations; market manipulations; insider trading; and violations by investment advisers, broker-dealers and investment banks. Ms. Bandy also oversaw high-profile matters involving cutting-edge or emerging areas of the securities laws, such as ESG disclosures. In 2021, she handled the SEC’s groundbreaking enforcement actions against a special purpose acquisition company and its target company. In the Foreign Corrupt Practices Act area, Ms. Bandy has significant experience in coordinating multijurisdictional resolutions with the Department of Justice and foreign regulators, working with monitors and independent compliance consultants, and advising on cross-border legal, policy and practice challenges.
She also led several SEC division-wide initiatives and “sweeps” concerning financial reporting and market risk and integrity issues, including the continuing Earnings Per Share (EPS) Initiative and the Rule 105 Initiative, which resulted in numerous actions against investment advisers. Under her leadership, the SEC also brought significant actions based on reporting violations in connection with mergers and acquisitions under the Williams Act, in addition to managing data-driven division priority initiatives. Prior to joining the SEC, she worked at an international law firm where she advised clients on securities matters and commercial litigation.
Committed to inclusion, Ms. Bandy helped lead a task force that established a multidimensional diversity and inclusion action plan for the Enforcement Division and created its first Diversity Committee in the SEC’s headquarters. She is a frequent speaker on SEC enforcement developments, corporate wrongdoing, government investigations, compliance and anti-corruption, and has been a securities law guest lecturer at the Georgetown University Law Center.