Adam S. Aderton

Adam Aderton, a former Co-Chief of the SEC’s Enforcement Asset Management Unit, is a Partner in Simpson Thacher’s Asset Management Regulatory and Enforcement Practice based in the Firm’s Washington, D.C. office. In addition to providing ongoing practical regulatory advice, Adam focuses on regulatory and enforcement matters, with a particular emphasis on the asset management industry. He conducts internal investigations and advises on complex regulatory examinations, enforcement inquiries, and litigation matters involving private equity funds, venture capital funds, hedge funds, BDCs, interval funds, tender offer funds, mutual funds and ETFs, as well as retail platforms and separately managed accounts.

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 is Co-Chair of the National Society of Compliance Professionals Private Funds Committee, participates in the Investment Company Institute’s Outside Counsel Advisory Group, and is on the Board of Advisors of the SEC Historical Society.

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 named to Securities Docket’s “Enforcement Elite” in 2024 and 2025.

Adam’s experience includes advising:

SEC Enforcement

• A private equity adviser and its employees in an SEC investigation involving calculation of fund management fees following dividend recapitalization transactions. The investigation was terminated with no action against the client.
• A hedge fund adviser in an SEC investigation involving the SEC’s whistleblower provisions. The investigation was terminated with no action against the client.
• An investment adviser in an SEC investigation involving the SEC’s pay-to-play rules. The investigation was terminated with no action against the client.*
• An investment adviser in an SEC investigation involving block trading practices. The investigation was terminated with no action against the client.*
• An investment adviser in an SEC investigation involving material non-public information controls. The investigation was terminated with no action against the client.*
• 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.*
• A software company CEO in an SEC investigation involving crypto asset registration. The investigation was terminated with no action against the client.*
• A large asset management platform in an SEC investigation involving potential violations of the Marketing Rule.
• An investment adviser to ETFs and its Chief Executive Officer in an SEC investigation involving ETF marketing.

SEC Examinations

• An adviser to a BDC in an SEC examination focused on conflicts of interest.
• A retail wealth management platform in an SEC examination focused on the Marketing Rule and fee and expense issues.
• A private equity fund adviser in an SEC examination focused on fee and expense calculations related to asset impairment.*

Internal Investigations

• A public company in an internal investigation involving executive trading.
• An investment adviser in an internal investigation involving allegations of misrepresentation of investment strategy.*
• An investment adviser in an internal investigation involving allegations of failure to enforce information barriers.*
• An investment adviser in an internal investigation involving accuracy of SEC filings.*

Adam received his J.D. from the 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 Hon. J. Frederick Motz of the U.S. District Court for the District of Maryland from 2004-2005.

*Experience prior to joining Simpson Thacher