Profil
Tracy serves as Co-Managing Shareholder of the Salt Lake City office. A former Regional Director of the U.S. Securities and Exchange Commission, Tracy represents companies, financial institutions, and individuals in government investigations and regulatory inquiries nationwide, most frequently those involving the SEC, the CFTC, and the Department of Justice. She is a trusted adviser to registrants, corporate boards, and high-profile individuals in a wide range of their most sensitive and confidential matters. As Utah Business Journal stated in 2025, Tracy “can easily handle a crisis for any client.”
Tracy joined GT after an almost decade-long tenure at the SEC, where she served in a variety of roles nationwide. 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 member of the SEC staff in San Francisco, Tracy brought several landmark enforcement actions, including the first public company cybersecurity disclosure case and the first “shadow” insider trading case. Tracy served for three years in the Division of Enforcement’s Cyber Unit (now called the Cyber and Emerging Technologies Unit), where she co-led its Cybersecurity & Regulated Entities group. Tracy also served as counsel to the Director of Enforcement in Washington DC, advising on priority matters and coordinating with the SEC’s national and international law enforcement partners.
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 and securities class actions. After law school she clerked for the Honorable Luis Felipe Restrepo on the U.S. District Court for the Eastern District of Pennsylvania.
Expertise
Erfahrung
- 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 and private companies regarding their disclosures and internal controls and procedures concerning cybersecurity incidents, frequently in parallel with DOJ, FBI, and FTC.°
- Investigated broker-dealers, investment companies, and investment advisers concerning cyber incidents and compliance with SEC-promulgated consumer data privacy safeguards.°
- Investigated and filed what was identified as the first “shadow” insider trading case against a biopharmaceutical executive in the Northern District of California.°
- 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 and foreign regulators.°
- Supervised and litigated an action against dozens of individuals and 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 and alleged Ponzi schemes.°
- Supervised the SEC’s action against a major nonprofit religious organization and its investment advisor for failing to file required forms with the SEC disclosing the value of assets in its securities portfolio.°
- Investigated and filed a fraud action against an Oregon-based investment group and its top executives for concealing the firm’s troubled financial conduction from investors.°
- Conducted a nationwide investigation into broker dealers and investment advisers who placed clients’ assets into an alleged fraudulent investment.°
- 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, and RICO conspiracy, winning a full acquittal after a six-month federal jury trial.°
°The above representations were handled by Ms. Combs prior to her joining Greenberg Traurig, LLP.
- U.S. Securities and 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 and Cyber Unit, 2017-2020; Co-Chair, Cybersecurity & Regulated Entities Group
Anerkennung durch den Markt
- Listed, The Best Lawyers in America, Litigation - Securities, 2027
- Listed, The Legal 500 United States, Media, Technology and Telecoms> Cyber Law (Including Data Privacy and Data Protection), 2026
- 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
- Board of Trustees, Legal Aid Society of Salt Lake
- Member, Law360 Editorial Advisory Board, Securities, 2025
Ausbildung
- J.D., University of Michigan Law School
- B.A., magna cum laude, Colby College
- U.S. District Court for the Eastern District of Pennsylvania, 2007-2008
- 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