Biography
Sanjay is deeply familiar with all aspects of SEC Enforcement, having risen through the ranks from Staff Attorney to Acting Director of the division. From 2021 through early 2025, Sanjay served in the top two senior-most positions in the Enforcement Division. Most recently, as Acting Director, Sanjay oversaw a nationwide team of approximately 1,400 lawyers, accountants, investigators, and industry specialists responsible for investigating and prosecuting federal securities law violations to protect investors and maintain the integrity of the markets. Sanjay earlier served as the Division’s Deputy Director from August 2021 to October 2024. In those front office leadership roles, Sanjay was involved in all policymaking and personnel matters relating to the Enforcement Division and oversaw its operations, which included the filing of more than 2,600 enforcement actions. The actions filed during this period covered the entire waterfront of securities law issues, including investment adviser and broker-dealer misconduct; insider trading; issuer disclosure violations; financial reporting and accounting fraud; audit firm violations; books and records, internal controls, and registration violations; offering frauds; market manipulation; bribery; and whistleblower protections. During this period, Sanjay also provided strategic advice and legal counsel to the Chair of the SEC and the other Commissioners about programmatically important Enforcement matters, and was involved in certain of the rule-makings spearheaded by the agency’s policy divisions.
Immediately prior to his front office roles, Sanjay served as a head of Enforcement in the New York Regional Office (NYRO) as its Senior Associate Director, and before then he was the inaugural Deputy Chief of SEC Enforcement’s nationwide Market Abuse Unit. Throughout his SEC career, Sanjay collaborated closely with his counterparts at various federal, state, and local criminal and civil law enforcement agencies throughout the country, as well as with FINRA, gaining in-depth knowledge of issues that are unique to parallel civil and/or criminal investigations and how to navigate them.
Beyond his deep understanding of the SEC’s Enforcement apparatus, Sanjay has vast expertise in substantive areas of law regarding securities enforcement, having brought or directly overseen hundreds of litigated or settled enforcement actions—and many more investigations that concluded without an action—over his career at the SEC, many of them involving groundbreaking issues. For example, during his time in NYRO, Sanjay conducted and/or closely supervised several multiyear, industry-wide investigations, which yielded some of the most consequential SEC enforcement actions in the past two decades. Of particular note, Sanjay led the SEC’s years-long focus on hedge fund insider trading, which uncovered the practice of corporate insiders sharing company secrets with traders while acting as paid consultants to “expert network” firms, resulting in landmark cases (and decisions) against more than 90 defendants, including most notably:
- Raj Rajaratnam and his advisory firm Galleon Management LP, and several high-level corporate insiders, resulting in the largest insider trading prosecution in the history of the DOJ, which conducted a parallel criminal investigation, and the largest-ever SEC insider trading settlement against an individual; and
- Primary Global Research, a leading expert network firm that shut down following the SEC’s charges against several individuals associated with the firm.
In addition, while in NYRO, Sanjay oversaw the SEC’s long-running investigation into certain practices in the handling of “pre-released” American Depositary Receipts, which led to 15 enforcement actions against depositary banks and broker-dealers and involved monetary remedies exceeding $430 million. Early in his career, Sanjay was the lead staff attorney on the SEC’s investigations to combat trading misconduct by member firms of various stock and options exchanges, including all member firms of the New York Stock Exchange and twenty of their floor specialists, resulting in monetary remedies approximating $315 million.
Sanjay is a recipient of the SEC’s 2021 Distinguished Service Award, the agency’s highest honorary award; the 2012 Stanley Sporkin Award, the Division of Enforcement’s highest honorary award; and the 2010 and 2012 Chairman’s Award for Excellence, among numerous other agency and division awards. He is also the recipient of the 2017 Legal Trailblazer Award conferred by the South Asian Bar Association of New York. Sanjay’s pioneering work at the SEC has been featured in numerous leading daily and weekly publications in the U.S. and in India, and he is extensively profiled in multiple best-selling books covering the government’s crackdown on hedge fund insider trading. Since 2025, he has been a recommended lawyer for Securities Litigation: Defense by Legal 500. Sanjay was selected among Lawdragon’s 2025 “500 Global Leaders in Crisis Management” list. Sanjay, who is also licensed as a certified public accountant, currently serves on the New York City Bar White Collar Crime Committee. He writes regularly about developments concerning the SEC’s Enforcement program.