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ARTICLE · 06 OCTOBER 2023

The SEC Flexes Its Enforcement Muscle In A Sanctions-Related Registration Case

Lewis Brisbois Bisgaard & Smith LLP
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On September 19, 2023, the U.S. Securities and Exchange Commission ("SEC") announced charges against Concord Management LLC ("Concord"), a Delaware limited liability company based in...

GlobalInternational Law
Andrew Zuckerman
Andrew Zuckerman
Jane Luxton
Jane Luxton
Andrew Pidgirsky
Andrew Pidgirsky
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Washington, D.C. (October 3, 2023) – On September 19, 2023, the U.S. Securities and Exchange Commission ("SEC") announced charges against Concord Management LLC ("Concord"), a Delaware limited liability company based in New York, and its principal Michael Matlin ("Matlin") for operating as unregistered investment advisers to a single client described in the SEC's complaint as a "wealthy former Russian political official living outside the United States." Although not specifically named by the SEC, according to recent media reports Concord's client is alleged to be Roman Abramovich (the "Client"), a Russian oligarch with ties to Vladimir Putin and the Russian Federation.

The SEC's complaint alleges that, from at least 2012 through 2022, Concord and Matlin provided continuous and regular supervisory and management services over a securities portfolio of private fund investments with billions of dollars of assets under management on behalf of the Client (estimated at

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