Andrew L. Bolton

Andrew L. Bolton

COUNSEL
FALLS CHURCH
T: 703.280.3383
F: 703.280.8943

With a distinguished career as a former government prosecutor, Mr. Bolton provides clients with a unique synthesis of high-stakes trial advocacy and sophisticated government knowledge. He has extensive experience in managing and trying complex felony cases and first-chairing high-stakes jury trials, including those involving homicides and other serious offenses. His expertise is rooted in a proven record of success in the courtroom, where he has supervised prosecutorial teams and coordinated with federal, state, and local law enforcement agencies.

This litigation experience is fortified by a robust background in government affairs. Mr. Bolton has routinely advised, engaged with, and briefed high-level stakeholders on intricate federal legislative and regulatory developments, as well as on updates concerning energy policy, regulatory developments, and State Attorneys General multi-state litigation. This dual expertise positions him to anticipate legal challenges from both judicial and political angles, providing clients with a forward-thinking and complete legal strategy.
 

Memberships & Activities

  • Member: Virginia State Bar

ARTICLES

Client Alert: The SEC Rewrote Its Enforcement Manual. Your Response Playbook Is Now Out of Date.

On February 24, 2026, the SEC released a sweeping overhaul of its Enforcement Manual, the internal guide that dictates how the Division of Enforcement conducts an investigation from initial contact through the Wells process and resolution. Manual revisions rarely make news. This one deserves it. Together with the Commission’s March 2025 decision to reclaim control over formal investigative orders, the new Manual changes the practical rules of engagement for any broker-dealer, investment adviser or associated person who receives a call, a letter or a subpoena from the staff. The majority of these changes tilt in favor of the defense, but only for those who recognize the opportunity and act on it.

Client Alert: The Compliance Problem Inside a Fraction of a Share

Edward D. Jones & Co. agreed to a $125,000 fine and a censure to settle FINRA charges that it had failed to report approximately 2.7 million fractional-share liquidations to a FINRA trade reporting facility. The matter resolved through a Letter of Acceptance, Waiver, and Consent, the negotiated procedure by which a firm consents to FINRA’s findings to resolve a disciplinary action without litigating it. The firm also paid the regulatory transaction fees owed on the unreported trades.