Christian R. Bartholomew is a partner in Weil’s Securities Litigation and Complex Commercial Litigation practices, where he concentrates exclusively on representing financial institutions and public companies and their officers and directors in securities enforcement and litigation matters. Drawing on a unique blend of experience at the Securities and Exchange Commission (SEC) – where he was an undefeated lead trial lawyer – and in private practice, Mr. Bartholomew leads the firm’s SEC and other government enforcement and litigation efforts in Washington and Miami.
Mr. Bartholomew represents clients in investigations conducted by the SEC, the Department of Justice (DOJ), the Financial Industry Regulatory Authority (FINRA), and other federal and state regulators, and has extensive experience handling large, complicated matters involving multiple regulators in multiple forums. As an accomplished former lead trial lawyer for the SEC, Mr. Bartholomew is also uniquely able to handle the related private litigation that typically arises as a result or during the course of these investigations, and has successfully resolved many such matters at both the trial and appellate level. In connection with these and other matters, Mr. Bartholomew also routinely conducts extensive internal investigations in which he leads teams of lawyers and paralegals in fact-finding efforts, and advises clients with respect to difficult self-reporting issues.
A recognized leader in the area of the SEC’s Dodd-Frank whistleblower rules, Mr. Bartholomew has represented a number of prominent financial institutions and public companies in internal and regulatory investigations regarding sensitive whistleblower allegations, and has also advised companies on strengthening their internal protocols to incentivize internal reporting. He has written and spoken extensively on the issue.
Mr. Bartholomew has represented well-known financial institutions in numerous multi-regulator, multi-litigation matters, and has handled and successfully resolved investigations and related litigation involving virtually every issue facing the industry, including sales practice, supervision, trading (market manipulation, markup/markdown, front-running, cherry-picking, best execution, order routing), revenue sharing, Chinese Wall/information sharing, insider trading, research, stock lending, options, and market timing issues.
Mr. Bartholomew’s efforts on behalf of public companies and public accounting firms have been similarly broad. He has successfully resolved numerous investigations and litigation matters involving financial statement disclosure and accounting issues (e.g., matters involving restatements and disclosure issues arising from revenue recognition, loan loss, lease, accounts receivable, loan swaps, and options “back-dating” accounting), as well as handling Foreign Corrupt Practices Act (FCPA), market, and insider-trading matters. In addition to his broad private practice, Mr. Bartholomew has twice been appointed as a federal receiver by United States District Courts in SEC enforcement cases.
Prior to joining Weil, Mr. Bartholomew was the Vice-Chairman of the Securities Litigation and Enforcement Practice at a major international law firm and the head of its Washington, DC Litigation Section.
Mr. Bartholomew earlier served for five years as Senior Trial Counsel for the Southeast Regional Office of the SEC, where he was lead trial counsel in numerous federal injunctive actions, administrative proceedings, and multi-defendant, multi-day trials and evidentiary hearings. Mr. Bartholomew was undefeated in all such matters during his tenure at the SEC and won several precedent-setting matters for the SEC, including:
- trying to judgment the first case under MSRB Rule G-17 to successfully charge a municipal bond dealer with unfair dealings without a related fraud charge;
- trying to judgment the first case to result in the revocation of a broker-dealer’s registration based solely on a failure to supervise charge;
- obtaining the first federal court decision to uphold the SEC’s power to compel a broker-dealer to turn over records to SEC examiners, subject only to reasonable time and place restrictions; and
- obtaining the first federal judgment to enjoin sales of so-called “viatical settlements.”
Mr. Bartholomew regularly publishes and speaks on a wide range of issues, including SEC and other government enforcement trends, corporate governance matters, and the development of internal controls and compliance programs. Based on his extensive thought leadership and robust experience, Mr. Bartholomew has been recognized as a leading securities lawyer by several industry publications, including The Best Lawyers in America and Chambers USA, the latter of which has noted his “excellent grasp of all of the key legal and regulatory issues…relationship with the regulatory staff members and a very strong work ethic.”