Jorge deNeve is a trusted legal advisor with nearly two decades of experience guiding clients through government enforcement actions, complex civil litigation, arbitrations, and sensitive internal investigations. Leveraging his background as a former SEC enforcement attorney, Jorge provides strategic counsel to a broad range of clients facing high-stakes disputes involving intricate financial and accounting matters.
Jorge has a proven track record of defending public companies, corporate boards, and senior executives in SEC enforcement actions and private litigation and arbitrations, alleging financial misconduct. His deep expertise in investigations has made him a go-to resource for corporate boards seeking to address internal allegations of fraud or misconduct involving senior officers. Jorge’s SEC experience, combined with his fluency in Spanish, has enabled him to efficiently manage internal investigations in Latin America and disputes involving Spanish-speaking witnesses and documents.
Jorge’s clients include financial institutions and advisors facing investigations by the SEC, DOJ, CFPB, and other state and federal regulators as well as private securities litigation and FINRA arbitrations. Jorge is also widely sought after by corporate officers to defend against insider trading investigations and related enforcement actions.
Jorge began his legal career at O'Melveny, where he focused on complex criminal and civil litigation, including defending accountants and a “Big Four” accounting firm. From 2003 to 2007, Jorge served as an enforcement attorney in the U.S. Securities & Exchange Commission's Los Angeles Regional Office, where he investigated high-profile cases involving financial statement fraud, disclosure fraud, insider trading, and auditor misconduct. He also served as General Counsel for one of O’Melveny’s former clients from 2010 to 2012, further broadening his legal and business acumen.
Clients rely on Jorge not only for his litigation and investigative skills but also for his ability to anticipate and mitigate risks in high-pressure situations. Whether defending against government investigations or resolving complex disputes, Jorge brings a combination of legal insight, regulatory knowledge, and practical problem-solving to help his clients achieve successful outcomes.
Get to Know Jorge
Get to Know Jorge
Board-Led and Internal Investigations
- Represented the Audit Committee of the Mattel Board of Directors in a high-profile investigation concerning allegations by an anonymous whistleblower of an accounting error that resulted in a misstatement of the toy maker’s income tax accounting
- Conducted an internal investigation for the Audit Committee of a manufacturing company regarding whistleblower claims of inaccuracies in tax calculations disclosed in earnings reports
- Conducted an internal investigation for the Audit Committee of a manufacturing company into allegations that operating costs were not being properly recognized and reported in accordance with generally accepted accounting principles (GAAP)
- Conducted an internal investigation for Audit Committee of an international technology company into whistleblower allegations of improper revenue recognition practices
- Conducted an internal investigation for defense contractor into whistleblower allegations of improper revenue recognition and misstatement of key financial metrics
- Conducted an internal investigation for a semiconductor company addressing whistleblower concerns about unsupported financial forecasts and their impact on public disclosures
- Conducted internal investigation on behalf of Audit Committee of a manufacturer into insider trading allegations against a company’s chief financial officer
- Conducted internal investigation for Special Committee of a digital media company into whistleblower claims of self-dealing and undisclosed conflict of interest by the chief executive officer
- Conducted internal investigation for Audit Committee of a non-profit organization into whistleblower allegations of prohibited transactions and financial misconduct by the chief executive officer
- Represented the Board of Directors of a state infrastructure agency in an internal investigation into multiple whistleblower complaints alleging improper contract expenditures and intentional misrepresentations by a senior executive
Civil Litigation and Arbitrations
- Successfully defended a prominent Wall Street bank in a high-stakes FINRA arbitration involving claims of insufficient disclosures regarding a US$60 million foreign exchange investment, unauthorized trading, and negligent supervision of a financial advisor, achieving a complete ruling of no liability for the client
- Secured dismissal at the pleading stage for Mexico's state-owned salt mining company in a multi-billion dollar civil lawsuit alleging breach of contract, effectively resolving significant legal exposure
- Achieved dismissal at the pleading stage for a healthcare insurer and its senior executives in securities class actions alleging inflated financial projections and failure to disclose materially adverse conditions, mitigating reputational and financial risk
- Defended an international technology company and its directors in complex state and federal shareholder derivative actions alleging breach of fiduciary duties related to a DOJ action, obtaining dismissal of all claims at the pleading stage
- Won dismissal at summary judgment for a partner at a consulting firm in a civil action alleging fraudulent overbilling, eliminating liability for the client
- Secured dismissal of an SEC enforcement action against the general counsel of a technology company and successfully defended parallel private securities claims alleging options backdating
- Achieved a favorable outcome for a public REIT company in litigation alleging violations of SEC whistleblower protection provisions, protecting the client's interests and reputation
- Defended a dually registered investment adviser in a FINRA arbitration involving claims of unsuitable investment recommendations and negligent account management
- Supervised Mexican counsel in parallel civil and criminal proceedings on behalf of a global automaker in a dispute with a Mexican national claiming distributor rights for a subsidiary, resulting in favorable settlement for client
- Represented a cosmetics company in a high-stakes action against a former executive accused of orchestrating a fraudulent kickback scheme and misappropriating trade secrets, achieving a favorable settlement for the client
- Defended Wall Street firm in FINRA arbitration demand related to trading of shares of company upon direct listing
Government Investigations Related to Financial Institutions
- Successfully defended a prominent private equity firm in an SEC investigation involving allegations of undisclosed conflicts of interest and improper fee allocation, protecting the client’s reputation and business operations
- Achieved a favorable result for a REIT-focused private equity firm in an SEC investigation into allegations of misleading marketing materials, mitigating regulatory exposure
- Defended a registered investment adviser in a complex SEC investigation regarding claims of misleading performance descriptions in marketing materials and significant compliance deficiencies under the Investment Advisers Act of 1940, resolving the matter efficiently while safeguarding the client’s interests
- Navigated an SEC investigation into a registered investment adviser’s disclosures related to expenses, performance, and revenue streams for certain investment products, foreclosing liability risks for the client
- Successfully represented a private equity firm in an SEC investigation concerning alleged failures to disclose conflicts of interest in transactions involving related parties, achieving a favorable outcome
- Defended a leading Wall Street bank in an SEC investigation into the adequacy of disclosures related to private offerings presented to the bank’s customers, effectively reducing regulatory scrutiny
- Defended national bank in multi-year CFPB investigation regarding digital payment service
- Defended an asset management company in a Department of Labor investigation regarding disclosure and allocation of fees on ERISA products
- Represented broker-dealer in SEC investigation into allegations of market manipulation of biotechnology companies
- Defended a public REIT company in SEC investigation into marketing practices and compliance with federal securities laws, including broker-dealer registration requirements, achieving a favorable outcome and protecting business operations
Government Insider Trading Investigations
- Successfully defended a Wall Street firm in an SEC investigation involving options trading in the firm’s proprietary account prior to a material disclosure by the subject company,
- Defended a major defense contractor in an SEC investigation into allegations of improper use of Rule 10b5-1 trading plans by senior officers, effectively mitigating regulatory exposure.
- Successfully defended a Wall Street bank in an SEC investigation concerning trading activity preceding a merger on which the bank had consulted
- Defended a global Wall Street bank in an SEC investigation into swap transactions with customers involving trading prior to a material disclosure by the company whose shares were traded, successfully navigating complex regulatory scrutiny
- Represented a supply chain company in a cutting-edge SEC investigation into alleged insider trading by officers under a novel shadow trading theory
- Successfully defended board members of a leading technology company in an SEC investigation into trading preceding the announcement of a merger involving the company, safeguarding their reputations
- Represented a consumer products retailer in an SEC investigation into insider trading allegations connected to a potential computer hacking scheme, managing intricate factual and legal issues
- Successfully defended a senior sales executive of a medical devices company in an SEC investigation into alleged insider trading by a friend prior to the company’s material announcement
- Represented an investor in a financial company in an SEC investigation into trading activity preceding a material disclosure after alleged communications with the company’s officers, successfully protecting the client’s interests and reputation
- Defended a private equity firm principal and his wife in an SEC investigation into trading of a potential acquisition target, resolving the matter while preserving the client’s standing in the industry
- Defended the founder of an options trading company in an SEC investigation into trading activity by a friend prior to a material company disclosure, effectively mitigating regulatory risks
- Defended former senior executive of insurance company in SEC investigation regarding trading under Rule 10b5-1 plan
Government Investigations Related to Corporate Activities
- Successfully defended a global public technology company in a complex SEC investigation into whistleblower allegations of improper revenue recognition under ASC 606
- Represented the Audit Committee of a construction company’s Board of Directors in a bilingual internal investigation into whistleblower allegations of FCPA violations involving activities in Mexico, skillfully presenting findings to the DOJ and SEC
- Represented the Audit Committee of a software technology company’s Board of Directors in an internal investigation into whistleblower allegations of improper revenue recognition of a material transaction, presenting conclusions to the SEC
- Defended a government bond issuer in a high-stakes SEC investigation into allegations of disclosure fraud regarding its financial condition, delivering strategic advocacy to protect the issuer’s interests
- Successfully defended the former CEO of a clothing manufacturer and retailer in an SEC investigation into allegations of fraudulent disclosures in a proxy statement
- Successfully defended a private food distributor and its CFO in an SEC investigation into allegations of misstated financial statements provided in private securities offerings, achieving a favorable resolution and protecting the CFO’s standing
- Defended the head of a Mexican subsidiary of an international retailer in an FCPA investigation by the SEC and DOJ, navigating cross-border legal challenges and protecting the client’s interests
- Defended the CFO of a sporting goods retailer in an SEC investigation into allegations of accounting errors allegedly improving reported metrics, delivering skilled defense and a favorable resolution
- Represented a consumer products company in an SEC investigation into disclosures of sexual misconduct allegations, managing sensitive reputational and regulatory issues with expertise
- Defended the Chief Compliance Officer of an international energy company in an SEC and DOJ investigation into allegations of FCPA and financial reporting violations, protecting client’s reputation
- Represented Mexican national employee of Mexican company public traded in the US in SEC investigation into allegations of fraudulent sales resulting in false financial statements
- Represented a computer software company in a PCAOB investigation regarding the independence of the company’s former auditor, protecting the client’s financial reporting integrity
Languages
- Spanish
Admissions
Bar Admissions
- California
Court Admissions
- US District Court, Central District of California
- US Court of Appeals, Ninth Circuit
Education
- University of Southern California Gould School of Law, J.D., 1998
- University of California at Los Angeles, B.S., Cognitive Science, 1992
Professional Activities
Clerkships
- Honorable Audrey B. Collins, US District Court, Central District of California (1999-2000)
Externships
- Honorable Harry Pregerson, US Court of Appeals, Ninth Circuit (1998)
Panelist
- “Best Practices for SEC White Collar Attorneys,” Los Angeles Federal Bar Association Event (March 2025)
- “International Arbitration and Mediation,” U.S.-Mexico Bar Association’s Annual Conference (September 2023)
- “SEC & PCAOB Updates,” Center for Corporate Reporting and Governance Annual SEC “Hot Topics” Conference (September 2018)
- “Avoid Club Fed: White Collar Crime and Corporate Investigations,” Hispanic National Bar Association Annual Convention (September 2013)
- “The Game Changer: Dealing with the Dodd Frank Act,” Hispanic National Bar Association Mid-Year Conference (March 2012)
Publications
- Co-Author, “SEC Continues Its Strong Focus on Rooting Out Whistleblower Impediments,” New York Law Journal (November 27, 2023)
- Co-Author, “The SEC is Pushing the Limits of Onsider Trading Enforcement,” Fortune (February 8, 2022)
- Co-Author, “Legitimate Expenses or Ill-Gotten Gains? How the SEC’s Revamped Disgorgement Remedy is Playing Out,” The Recorder (August 9, 2021)
- Author, “Maintaining An Effective Compliance Program When the SEC Enforcement Staff Comes Knocking,’ in SEC Compliance Best Practices, 2014 ed.: Leading Lawyers on Understanding New Regulations and Developing Compliance Strategies (Inside the Minds)
- Co-Author, “FCPA Enforcement Lacks Transparency,” Los Angeles Daily Journal (August 18, 2014)
Board Member
- Board of Directors, Community Legal Aid SoCal (joined October 2022)
- Board of Trustees, Mexican American Bar Foundation (joined April 2014)
Corporate & Government Experience
- Enforcement Attorney, U.S. Securities & Exchange Commission's Los Angeles Regional Office