SEC v. Lawrence Billimek and Alan Williams (front running, 2022)

Settled

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In December 2022 the SEC sued Lawrence Billimek and Alan Williams over an alleged front-running scheme that produced about $47 million in profits. On September 17, 2026 the SEC filed proposed consent judgments with disgorgement of $12,684,000 (Billimek) and $34,627,659 plus $12,027,557.75 of interest (Williams), all deemed satisfied by a criminal forfeiture order. The release says they are subject to court approval, which I did not confirm.

The record

What was ordered

Civil penalty

—

Disgorgement

$47.3m

Prejudgment interest

$12m

Total relief

$59.3m

Alleged gain

$47m

A dash means the release did not state a figure we could extract, not that the figure is zero. Penalty and disgorgement are stored separately so aggregates across the library do not double-count the same dollars.

What is alleged to have happened

The Securities and Exchange Commission announced this action on December 20, 2022 as litigation release LR-25595, in SEC v. Billimek and Williams, civil action 1:22-cv-10542 in the Southern District of New York, filed December 14, 2022. The defendants are Lawrence Billimek and Alan Williams (2 individuals, 0 entities).

The complaint alleges that since at least September 2016 Billimek told Williams about his employer's planned market-moving trades before they were executed, and that on the same day Williams traded the same securities ahead of, or while, the employer's large orders were being placed, closing his positions once the price moved as expected. The SEC says the scheme produced more than $47 million, and that its analysts used the Consolidated Audit Trail to trace Williams's trading. The charges include Securities Act Section 17(a), Exchange Act Section 10(b) and Rule 10b-5 and, for Billimek, Investment Company Act Section 17(j).

The U.S. Attorney's Office for the Southern District of New York announced criminal charges against both men. The civil matter is recorded as filed; no relief has been ordered and the allegations remain unproven. An earlier version showed the status as unknown.

Outcome. SEC Litigation Release 26645 (September 22, 2026) says that on September 17, 2026 the SEC filed proposed final judgments in S.D.N.Y. No. 22-cv-10542 that, if approved, would settle the case. Billimek and Williams consented to permanent injunctions under Section 17(a), Section 10(b) and Rule 10b-5 (and, for Billimek, Section 17(j) of the Investment Company Act); the proposed judgments order disgorgement of $12,684,000 against Billimek and $34,627,659 plus $12,027,557.75 of prejudgment interest against Williams, all deemed satisfied by the order of forfeiture in the parallel criminal case, United States v. Billimek and Williams, 22 cr. 675. The release does not say the court has entered the judgments, so the settlement date recorded is the filing date, and I did not check whether the court approved them. No civil penalty or sentence is stated.

For the regulator's own account of the facts, read the primary document linked above.

What technique is this, and how does it work?

This action is tagged with one technique in our taxonomy. The tagging is ours: regulators charge statutory provisions, not technique names, so the mapping is an editorial judgement described in our editorial policy.

• Front running — see how it works, what statute it engages, and every other action tagged the same way.

Timeline

1. 2022-12-20 Litigation release published
2. 2026-09-17 SEC files proposed consent final judgments (subject to court approval)

Primary documents

Everything on this page derives from the documents below. Where our summary and the primary document disagree, the primary document is right.

• SEC litigation release
• SEC litigation release 26645 (proposed settlement)

The linked release is a work of the United States government and is not subject to copyright. Our summary and narrative above are our own writing.

Related actions

Other actions in the library sharing at least one technique tag with this one.

Record added September 10, 2026. submit a correction.