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Tracy S. Combs

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4 Embarcadero Center, Suite 3000, San Francisco, CA 94111-5983

Litigation, Commercial Litigation, White Collar Defense & Investigations and 5 more

About Tracy S. Combs

Tracy serves as Co-Managing Shareholder of the Salt Lake City office. A former Regional Director at the U.S. Securities and Exchange Commission, she represents corporations, financial institutions, and individuals in a wide range of federal and state government investigations, litigation, and regulatory inquiries nationwide, including those involving the SEC, the Department of Justice, and state Attorneys General. She also counsels clients in complex business disputes, tort litigation, and cybersecurity matters. As Utah Business Journal’s Legal Elite edition stated in 2025, Tracy can “navigate a wide range of legal situations and... easily handle a crisis for any client.”

Tracy joined GT after an eight-year tenure at the SEC, where she served in a variety of roles in San Francisco and Salt Lake City. Most recently, Tracy served as Director of the SEC’s Salt Lake Regional Office, where she oversaw some of its most high-profile cases. As a former SEC trial and investigative attorney in San Francisco, Tracy brought several groundbreaking enforcement actions, including the SEC’s first public company cybersecurity disclosure case and its first “shadow” insider trading case. Tracy served for three years in the Division of Enforcement’s former Cyber Unit, where she co-led its Cybersecurity & Regulated Entities group. In 2021 to 2022, Tracy served as counsel to the Director of Enforcement, advising on priority matters and coordinating with the SEC’s criminal and civil law enforcement partners nationwide.

Prior to her government service, Tracy was a litigator at a large law firm in Philadelphia and New York, with a focus on high-stakes white collar criminal matters, securities class actions, and complex commercial disputes, and clerked for the Honorable Luis Felipe Restrepo in the U.S. District Court for the Eastern District of Pennsylvania.

Judicial Clerkships

•Hon. Luis Felipe Restrepo, U.S. District Court for the Eastern District of Pennsylvania, 2007-2008

Recognition & Leadership

Awards & Accolades

•Listed, Utah Business Magazine, “Utah Legal Elite - White Collar & Investigations,” 2025
•Securities and Exchange Commission, Chairman’s Award for Serving the Interest of Main Street Investors, 2018 (team award)
•Securities and Exchange Commission, Director’s Awards, Division of Enforcement, 2017 and 2018

 

Tracy S. Combs (San Francisco, California) View website

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Services

Areas of Law

  • Litigation
  • Commercial Litigation
  • Other 6
    • White Collar Defense & Investigations
    • Corporate Governance & Compliance
    • Financial Services Litigation
    • Securities Litigation
    • Data Privacy & Cybersecurity
    • Complex Torts

Practice Details

  • Firm Information
    Position
    Shareholder
    Firm Name
    Greenberg Traurig, LLP
  • Representative Cases & Transactions
    Cases
    Experience: Cybersecurity: Filed the SEC's first public company cyber incident disclosure case involving a company's failure to disclose a massive data breach perpetrated by a state actor.
    Investigated public
    private companies regarding their disclosures
    internal controls
    procedures concerning cybersecurity incidents, frequently in parallel with DOJ, FBI,
    FTC.
    Investigated broker-dealers, investment companies,
    investment advisers concerning cyber incidents
    compliance with SEC-promulgated consumer data privacy safeguards.
    Insider Trading: Investigated
    filed what was identified as the first 'shadow' insider trading case against a biopharmaceutical executive in the Northern District of California.
    SEC Reporting: Supervised the SEC's $413 million scienter-based fraud action in the Southern District of New York against a major European bank regarding its disclosures about its anti-money laundering compliance program. The SEC's settlement was part of a global resolution of over $2 billion with DOJ
    foreign regulators.
    Offering Fraud
    Ponzi Schemes: Supervised
    litigated an action against dozens of individuals
    entities related to the perpetration of a more than $450 million Ponzi scheme in the Las Vegas, Nevada area.
    Supervised numerous investigations concerning alleged unregistered securities offerings
    alleged Ponzi schemes.
    Investment Advisers
    Broker-Dealers: Supervised the SEC's action against a major nonprofit religious organization
    its investment advisor for failing to file required forms with the SEC disclosing the value of assets in its securities portfolio.
    Investigated
    filed a fraud action against an Oregon-based investment group
    its top executives for concealing the firm's troubled financial conduction from investors.
    Conducted a nationwide investigation into broker dealers
    investment advisers who placed clients' assets into an alleged fraudulent investment.
    White Collar Criminal Defense: In private practice prior to service at the SEC, member of a trial team representing an attorney at a large firm criminally charged with securities fraud, wire fraud,
    RICO conspiracy, winning a full acquittal after a six-month federal jury trial.
    The above representations were h
    led by Ms. Combs prior to her joining Greenberg Traurig, LLP.

    Government Experience: U.S. Securities
    Exchange Commission, 2015-2024
    Regional Director, Salt Lake Regional Office, 2022-2024
    Trial Attorney, Division of Enforcement, 2021-2022
    Counsel to the SEC Director of Enforcement, 2021-2022
    Senior Counsel, Division of Enforcement, 2015-2021
    Member, Crypto Asset
    Cyber Unit, 2017-2020
    Co-Chair, Cybersecurity & Regulated Entities Group
  • Additional Links
    http://https//www.gtlaw.com/

Experience

  • Bar Admission & Memberships
    Admissions
    California
    New York
    Utah
    U.S. District Court for the Central District of California
    U.S. District Court for the Eastern District of California
    U.S. District Court for the Northern District of California
    U.S. District Court for the Southern District of California
    U.S. District Court for the Eastern District of Pennsylvania
    U.S. District Court for the Southern District of New York
    U.S. Court of Appeals for the Ninth Circuit
    U.S. Court of Appeals for the Tenth Circuit
    2007, Pennsylvania
    Memberships

    Professional & Community Involvement

    •Member, Law360 Editorial Advisory Board, Securities, 2025

  • Education & Certifications
    Law School
    University of Michigan Law School
    Class of 2006
    J.D.
    Other Education
    Colby College
    Class of 2003
    B.A.
    magna cum laude

Contact Tracy S. Combs

Share Holder at Greenberg Traurig, LLP
Not yet reviewed

4 Embarcadero Center, Suite 3000San Francisco, CA 94111-5983U.S.A.

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Fax: 415 705-2501
(215) 988-2757

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Attorneys FAQs

  • Is this attorney admitted to the bar in more than one state?
    Yes, Tracy S. Combs is admitted to practice in California, New York, Pennsylvania and Utah.
  • Is this attorney admitted to practice in any U.S. Federal Courts?
    Tracy S. Combs is admitted to practice before the United States Court of Appeals for the Ninth Circuit, United States Court of Appeals for the Tenth Circuit, United States District Court for the Central District of California, United States District Court for the Eastern District of California, United States District Court for the Eastern District of Pennsylvania, United States District Court for the Northern District of California, United States District Court for the Southern District of California and United States District Court for the Southern District of New York.
  • How many attorneys are in this law firm?
    Greenberg Traurig, LLP has 2750 attorneys at this location.
  • What law school did this attorney attend?
    Tracy S. Combs attended University of Michigan Law School.
  • What year was this attorney's law firm established?
    Greenberg Traurig, LLP was established in 1967.

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