In the Matter of Spencer C. Barasch, AP File No. 3-14891. On May 24, 2012, the SEC issued an Order Instituting Administrative Proceedings, Making Findings and Imposing Remedial Sanctions against Spencer Barasch, a former enforcement official in the SEC’s Forth Worth office. Mr. Barasch was the Associate District Director for Enforcement in the SEC’s Forth Worth office from 1998 to 2005. While at the SEC, he was “personally and substantially” involved in decisions regarding allegations that entities associated with Robert Allen Stanford, including Stanford Group Company, violated the federal securities laws. After leaving the SEC, Barasch contacted the SEC’s Ethics Office about his ability to represent Stanford Group Company before the Commission. He was informed that he was permanently barred from doing so. About a year later, Stanford Group Company retained Barasch regarding an SEC investigation. After a formal order of investigation was issued, Barasch contacted SEC staff and attempted to obtain information about the investigation. He billed 12 hours for his work. The SEC ethics office told Barasch that he was barred from representing Stanford Group Company in the pending SEC investigation. The SEC Order concludes that he violated 18 U.S.C. § 207(a)(1), which prohibits former executive branch employees from communicating with federal agencies on matters in which the agency is a party or has an interest and in which the person personally and substantially participated while employed by the government. The Order bars Barasch from appearing or practicing before the SEC for one year. In addition, Barasch paid $50,000 to the Department of Justice to settle civil claims that he violated 18 U.S.C. § 207.
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