Chris Davis, JD, CPA
Partner, Gov. Investigations & Compliance Practice Group Leader

Many lawyers use the same playbook in every case, regardless of the issues and dollar amounts involved. My clients are facing challenging problems during a government investigation or commercial dispute that puts everything on the line, and the standard playbook isn’t the solution. I focus on finding the most creative, cost-efficient strategy that will help my clients avoid prosecution, minimize financial impact and put their lives and businesses back on track.

Chris Davis serves as Gray Reed's Government Investigations & Compliance Practice Group Leader. Chris guides businesses and individuals through high-stakes investigations, criminal proceedings and civil enforcement actions brought by various federal and state agencies, including those involving allegations of securities fraud, insider trading, healthcare fraud, FCPA violations, False Claims Act violations and pay-to-play schemes. He also helps his clients resolve a variety of complex commercial disputes, both before and after litigation has been filed. Chris represents clients across the country and internationally spanning several industries, including healthcare, energy, financial services, fintech, real estate, technology and retail.

As a former government trial lawyer, Chris brings unique experience and an insider perspective to the firm’s white-collar defense practice. He previously served as a Senior Trial Counsel in the SEC's Fort Worth Regional Office, which covers Texas, Oklahoma, Arkansas and Kansas. In that role, he was responsible for leading litigation efforts throughout the country against individuals and entities charged with violating the federal securities laws. Chris investigated and prosecuted many cases involving a variety of high-profile and first-impression matters, ranging from cryptocurrency-based securities and Ponzi schemes to accounting fraud and insider trading.

A licensed CPA since 2000, Chris spent seven years in the private sector before entering law school, primarily in management consulting for a Big Four accounting and consulting firm. Chris leverages his experience as a government regulator, CPA and management consultant to advise clients on best practices for minimizing regulatory and business risks. In addition to helping clients develop proactive compliance policies and procedures, Chris conducts internal investigations to defuse compliance issues quickly before they give rise to an investigation or litigation.

Before joining the SEC in 2010, Chris worked in the trial department of a large international law firm. He has deep experience as lead counsel in civil and commercial litigation matters involving a broad range of issues, including claims arising from his white-collar practice, intellectual property, contract disputes, professional malpractice, plus many more.

Chris is a regular presenter on cutting-edge topics such as cybersecurity and digital currencies, as well as government enforcement and compliance issues.

Representative Experience

Government Experience

  • Achieved the SEC’s first ever emergency appointment of a receiver in a case stemming from a fraudulent cryptocurrency offering.
  • As part of a coordinated effort with the Department of Justice, FBI and CFTC, brought the SEC’s first ever action against an unregistered online security-based swaps dealer.
  • Successfully obtained emergency relief and multi-million-dollar final judgments in a $33 million securities offering fraud targeting professional athletes.
  • Investigated, charged and obtained favorable litigated judgments against three former executives, including the CEO and CCO, following a three-week administrative trial in connection with the $7 billion Stanford Ponzi scheme.
  • Investigated and negotiated settlements with an NYSE-listed energy company and its former CFO, CAO, auditor and SOX consultant based on the company’s failure to evaluate and disclose internal control weaknesses.
  • Obtained settled final judgments against a NASDAQ-listed specialty retail company and its former COO based on the company’s recurring accounting misstatements in its public filings.
  • Obtained an emergency temporary restraining order, the appointment of a receiver and a $65 million final judgment in an international foreign-exchange trading scheme that involved extensive coordination with authorities from Australia and the Netherlands.
  • As part of a coordinated effort with the Department of Justice, Secret Service, FBI and Texas State Securities Board, obtained an emergency temporary restraining order, the appointment of a receiver and a $35 million final judgment in an oil and gas securities offering fraud.

Law Firm Experience

  • Successfully defended an international telecommunications company in a multi-billion-dollar patent infringement suit.
  • Successfully defended a major international law firm against professional malpractice claims stemming from the firm’s representation of an individual charged by the SEC, Department of Justice and IRS with various civil and criminal violations.
  • Successfully defended a Big Four accounting firm against professional malpractice claims stemming from the firm's audit activities.
  • As part of a bankruptcy proceeding, helped the debtor-in-possession company obtain a multi-billion-dollar fraudulent transfer judgment.
  • Negotiated a favorable settlement on behalf of a subcontractor in a dispute involving the general contractor and other subcontractors.
  • Successfully defended a major pharmaceutical company in a personal injury class-action suit involving thousands of potential claimants across the country.
Thought Leadership / News
  • Selected by his peers for inclusion in Woodward/White, Inc.'s The Best Lawyers in America in the fields of White-Collar Defense (2024), Securities Litigation (2024) and Securities Regulation (2024)
  • Recognized as a leading White-Collar Crime & Government Investigations lawyer in Texas by Chambers & Partners USA (2024)
  • SEC Director’s Award (2013, 2015 - 2017)
Organizational Involvement

Professional Involvement, Memberships & Affiliations

  • Texas Blockchain Council – Board Member (2024 – present)

Community Involvement, Memberships & Affiliations

  • Carry The Load – Team Leader and Fundraiser
  • Trophy Club Roanoke Youth Baseball Association – Board Member
  • J.D., with honors, The University of Texas School of Law (2005)
  • B.B.A., Baylor University (1995)
Bar Admission
  • Texas
Court Admissions
  • United States District Court, Eastern District of Texas
  • United States District Court, Northern District of Texas
  • United States District Court, Southern District of Texas
  • United States District Court, Western District of Texas
When I Feel Most At Home
  • Coaching my 8-year-old son’s baseball team
  • Having my weekly daddy-daughter date with my daughter after her dance class
  • Visiting the wine country with my wife or Telluride with the whole family
  • Firing up the Green Egg and smoking ribs while watching college football
  • Hunting, fishing or playing golf (poorly) with my buddies