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Luke T. Cadigan

Fax +1.617.261.3175

Luke Cadigan is an experienced trial attorney and litigator. Mr. Cadigan concentrates his practice on securities enforcement matters, internal investigations, regulatory compliance, and related litigation.

Professional Background
Prior to joining K&L Gates, Mr. Cadigan was an Assistant Director in the Enforcement Division of the Securities and Exchange Commission, serving that role in both the Boston Regional Office and in the SEC’s Foreign Corrupt Practices Act Unit. He managed investigations conducted by staff attorneys and accountants into, among other things, matters relating to investment advisers, broker-dealers, insider trading, accounting fraud, offering fraud, and whistleblower complaints. Mr. Cadigan also oversaw investigations into potential FCPA violations and, serving as a member of the agency’s Cross Border Working Group, he supervised investigations into the accounting practices of Chinese and other foreign companies trading on U.S. markets.

Before becoming an Assistant Director, Mr. Cadigan spent more than seven years as Senior Trial Counsel at the SEC. In that role, he investigated and litigated dozens of high-profile matters. As lead counsel, he also successfully tried several complex matters, both in federal court and the SEC’s administrative forum. These matters related to, among other things, allegations of insider trading by a hedge fund employee, accounting fraud, a pay-to-play scheme by a former state senate majority leader, fraud by an investment adviser, and fraud by a broker-dealer (resulting in then the largest penalty awarded in an SEC administrative proceeding). He was a recipient of the Chairman’s Award for Excellence in 2002 and 2007 and the Division of Enforcement Director’s Award in 2007 and 2008.

Before joining the SEC, Mr. Cadigan was a senior associate at another law firm in Boston, focusing his practice on government enforcement and complex commercial litigation. He also served as a law clerk for the Honorable Edward F. Harrington of the United States District Court in Massachusetts and as a Special Assistant District Attorney in Middlesex County, Massachusetts.

Speaking Engagements

  • “Compliance Workshop for Broker-Dealers and Investment Advisers” (panelist), K&L Gates, Boston, Massachusetts, June 21, 2016
  • “Insider Trading After the 2nd Circuit Decision in Newman: Is it Back to the Future?” (panelist), Boston Bar Association, March 4, 2015
  • “SEC and FINRA Examination Priorities for 2015” (panelist), Boston Bar Association, February 5, 2015
  • “SEC Asset Management Unit and Exam Program Areas of Focus for 2015” (panelist), K&L Gates Investment Management Training Program, Boston, Massachusetts, December 9, 2014
  • “Meet the Regulators: A Conversation with Senior SEC Enforcement Officials” (panelist), Boston Bar Association, December 2, 2014
  • “Investigations of Operation Lava Jet in the United States” Podcast Rio Bravo, November 26, 2014
  • “The SEC’s Continued Focus on Risk Management, Marsh/FINPRO Investment Adviser Risk Management Seminar, November 13, 2014
  • “Insider Trading: Practical Considerations in an Era of Aggressive Government Enforcement” (panelist), K&L Gates Hedge Fund Program, Boston, Massachusetts, September 30, 2014
  • "The SEC Enforcement Division's Renewed Interest in Structured Products" (panelist), K&L Gates webinar, June 20, 2014
  • “SEC Enforcement Issues” (panelist), CPE Revenue Recognition Conference 2014, Boston Massachusetts, June 19, 2014
  • “Whistleblowers: A Practical Discussion of How to Respond to Claims and Address Risks” (panelist), Boston Bar Association CLE, Boston, Massachusetts, June 16, 2014
  • “Data Privacy and Cybercrime's Impact on the Financial Services Industry” (panelist), K&L Gates Webinar, Boston, Massachusetts, April 8, 2014
  • "Fixing the Financial Industry's Broken Windows" (panelist), Global Association of Risk Professionals Webinar, March 11, 2014
  • “Examination Priorities for 2014 from Regulators at the CFTC, FINRA, NFA, and SEC” (panelist), Boston Bar Association, February 27 2014
  • “The SEC Settlement Process: Legal and Practical Considerations” (panelist), Boston Bar Association, February 10, 2014
  • “Dealing with the Complex Issues that Arise When Responding to SEC Subpoenas for Documents” (panelist), K&L Gates Webinar, December 12, 2013
  • “SEC Asset Management Unit and Exam Program Areas of Focus for 2014” (panelist), K&L Gates Investment Management Training Program, Boston, Massachusetts, December 11, 2013
  • “SEC Examination and Enforcement Program Priorities: The Regulators’ Perspective” (panelist), NRS 28th Annual Fall Investment Adviser & Broker-Dealer Compliance Conference, October 10, 2013
  • “SEC Enforcement Issues” (panelist), CPE Revenue Recognition Conference 2013, Boston Massachusetts, June 21, 2013
  • “Regulatory Update” (panelist), ACS Financial Accounting & Reporting Update Conference, Boston, Massachusetts, June 13, 2013
  • “Insiders and Outlaws: The High Stakes World of Whistleblowing” (panelist), Littler Mendelson Executive Employer Conference, Scottsdale, Arizona, May 8, 2013
  • The New Whistleblower Regime Under Dodd-Frank: The First 18 Months” (panelist), Boston Bar Association CLE, Boston, Massachusetts, January 14, 2013
  • “Looking Forward: Anticipating SEC and FINRA Exam Priorities for 2013” (panelist), K&L Gates, Boston, Massachusetts, November 26, 2012
  • “SEC Asset Management Unit, SEC Focus Points, and Developments in Enforcement,” K&L Gates Investment Management Training Program, Boston, Massachusetts, November 2, 2012
  • “Internal Reports of Violations: How to Encourage and Handle Them” (panelist), Agenda Exchange Webinar on Whistleblowers, October 18, 2012
  • “SEC Enforcement Issues” (panelist), CPE Revenue Recognition Conference 2012, Boston Massachusetts, June 22, 2012
  • “Anticorruption Law Developments” (panelist), 2012 AICPA International Business Conference, Washington, DC, June 11, 2012
  • “Regulatory Update” (panelist), ACS Financial Accounting & Reporting Update Conference, Boston, Massachusetts, June 12, 2012
  • “Securities Fraud 2012: Recent Developments in Enforcement and How SEC Administrative Trials May Alter the Landscape” (panelist), Boston Bar Association, Boston, Massachusetts, May 16, 2012
  • “What Investment Advisors Need to Know about the SEC's New Enforcement and Exam Initiatives,” K&L Gates Webinar, February 28, 2012
  • “An Insider's Look at the SEC: How Changes in the Enforcement Division Will Impact Your Business,” Association of Corporate Counsel (Northeast Chapter), February 9, 2012
  • “Dodd-Frank’s Whistleblower Provisions: Impacts on FCPA Compliance Efforts,” K&L Gates Webinar, October 2011
  • “Introduction to SEC Investigations” (panelist), Boston Bar Association, Boston, Massachusetts, September 14, 2011
  • “Litigation Considerations” (panelist), 2011 SEC FCPA Boot Camp, SEC Headquarters, Washington, D.C., June 27-29, 2011
  • “SEC Enforcement Update” (panelist), 2011 CPE Conference on Revenue Recognition: Current Industry Trends & Strategies in Financial Reporting, Boston, Massachusetts, June 24, 2011
  • “Trends in FCPA Enforcement” and “Whistleblowers” (panelist), CFO Ethics summit, Wellesley, Massachusetts, June 23, 2011
  • “The Foreign Corrupt Practices Act: Insights and Issues” (panelist), 2011 AICPA IBC Conference, New York, New York, June 15, 2011
  • “SEC & Regulatory Update” (panelist), ACS Financial Accounting & Reporting Update Conference, Boston, Massachusetts, June 9-10, 2011
  • “Securities Enforcement: What’s Up at the SEC – Whistleblowing, Insider Trading and the FCPA” (panelist on FCPA panel), Boston Bar Association, Boston, Massachusetts, April 6, 2011
  • “SEC Enforcement Update” (speaker), Society of Corporate Secretaries and Governance Professionals, Hartford, Connecticut, March 2011
  • “Litigation Considerations” (panelist), 2010 SEC FCPA Boot Camp, SEC Headquarters, Washington, D.C., July 26-28, 2010
  • “The SEC and the Profession” (panelist), Accountant’s Liability: Litigation and Issues in the Financial Crisis, ALI-ABA, Boston, Massachusetts, July 8, 2010


  • Massachusetts Super Lawyer 2012-2015
  • New England’s Top Rated Lawyers (ALM) 2012-2014
  • AV® Preeminent™ (Martindale-Hubbell’s® Lawyer Ratings) 2012-2016

Professional Activities

  • Co-Chair, Financial Services Section, Boston Bar Association
Government Enforcement
Mr. Cadigan has handled investigations, examinations, and inquiries by, among others, the U.S. Securities and Exchange Commission (SEC), the U.S. Department of Justice (DOJ), U.S. Attorney’s Offices, Attorney General’s Offices, the Financial Industry Regulatory Authority (FINRA), the Massachusetts Securities Division, and the U.S. Department of Labor. The matters include the following:

  • Defending private placement agent in SEC enforcement action in federal court arising from $75 million municipal bond offering;
  • Represented manufacturer in SEC and DOJ investigations arising from self-report of potential Foreign Corrupt Practices Act (FCPA) violations in China, resulting in rare SEC non-prosecution agreement (NPA) and public DOJ declination;
  • Represented numerous entities and individuals, including chairman of board of directors, investigated for insider trading by the SEC and/or the U.S. Attorney’s Office (USAO);
  • Represented investment advisers, broker-dealers, and employees in various SEC, USAO, and DOJ investigations into fee disclosures and potential conflicts of interest;
  • Conducting internal investigations in South America and Asia into possible FCPA violations;
  • Representing employee in SEC and DOJ investigations into possible FCPA violations in Africa;
  • Representing bond counsel in SEC investigation into municipal offering;
  • Represented individuals and entities in criminal and civil investigations into possible violations of the False Claims Act and the Anti-Kickback Statute;
  • Represented investment advisers in SEC investigations and enforcement actions arising from issues related to performance advertising;
  • Represented executive in SEC and DOJ investigations into possible FCPA violations arising from hiring practices;
  • Representing investment advisers in SEC investigations into suspected pay-to-play violations;
  • Represented broker-dealers and employees in SEC and FINRA investigations and/or enforcement actions arising from alleged best execution violations;
  • Advised numerous investment advisers and broker dealers in connection with SEC examinations

Civil Litigation
Among the civil matters Mr. Cadigan has handled are as follows:

  • Represented supermarket chain and various committees of its board of directors in connection with lawsuits and/or various disputes involving shareholders, directors, officers, and employees;
  • Represented defendant in SEC enforcement action in federal court alleging that he was an unregistered broker dealer;
  • Represented individuals and entities in investigation and enforcement action by Massachusetts Securities Division into supposed misrepresentations and unregistered activities;
  • Represented software company in lawsuits brought in Massachusetts and Texas arising from stock purchase agreement;
  • Represented holders of trust preferred securities in connection with dispute against issuer concerning proposed sale of underlying assets;
  • Representation of investment advisers in connection with third-party subpoenas for depositions and documents;
  • Routinely advise numerous investment advisers on regulatory and litigation risks and exposure