SEC Seeks Final Judgments in $47 Million Billimek and Williams Front-Running Case
SEC proposes final judgments against Lawrence Billimek and Alan Williams over a front-running scheme generating about $47 million in illegal trading profits.
Summary
On September 17, 2026, the SEC filed proposed final judgments in the Southern District of New York against former financial services professional Lawrence Billimek and associate Alan Williams. The filing would settle Securities and Exchange Commission v. Lawrence Billimek and Alan Williams, No. 22-cv-10542-JHR, filed December 14, 2022. The SEC’s September 22 release said court approval remains required for the settlement of allegations that their multiyear front-running scheme generated approximately $47 million in illegal trading profits.
The complaint alleges that, from at least September 2016, Billimek, then employed by an unnamed major asset management firm, tipped Williams before market-moving employer trades. Williams allegedly traded the same securities that day, before execution or during multiple large orders, then closed positions after expected price movements. Both consented to permanent injunctions under Securities Act Section 17(a), Exchange Act Section 10(b), and Rule 10b-5. Billimek also consented under Investment Company Act Section 17(j) and Rules 17j-1(b)(1) and (3). The judgments require Billimek to disgorge $12,684,000 and Williams $34,627,659 plus $12,027,557.75 in prejudgment interest, deemed satisfied by forfeiture in United States v. Lawrence Billimek and Alan Williams, 22 cr. 675 (PGG). The Market Abuse Unit’s Analysis and Detection Center originated the case using trading-pattern data analysis. David Bennett, Jeffrey Oraker, and John Rymas investigated under Danielle Voorhees and unit chief Joseph Sansone. Denver Office lawyers Terry Miller and Gregory Kasper conducted and supervised the litigation, respectively.
Positives
- Both defendants consented to permanent securities-law injunctions, allowing the civil enforcement action to conclude if the court approves the judgments.
- Billimek’s $12,684,000 disgorgement and Williams’s $34,627,659 disgorgement plus $12,027,557.75 interest are deemed satisfied through criminal forfeiture.
- The SEC’s Analysis and Detection Center identified the suspicious trading patterns using data-analysis tools.
- The proposed judgments address violations alleged under the Securities Act, Exchange Act, and, for Billimek, the Investment Company Act.
Risks & concerns
- The alleged multiyear front-running scheme generated approximately $47 million in illegal trading profits.
- The alleged conduct began by at least September 2016, indicating that the trading continued for years before the SEC’s 2022 complaint.
- Billimek allegedly disclosed market-moving employer orders, enabling Williams to trade ahead of or during the asset manager’s large transactions.
- Williams faces $34,627,659 in disgorgement and $12,027,557.75 in prejudgment interest under the proposed judgment.
- The September 17, 2026 final judgments remain proposed and cannot resolve the SEC action without court approval.
