Sullivan
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Biography

Erika is an associate in the Litigation Department of the firm’s Boston office. Her practice focuses on commercial litigation, including complex commercial, environmental, employment and securities matters. Her experience further includes representing clients in bankruptcy matters, including Chapter 11 cases, as well as working with both borrowers and creditors in all aspects of complex insolvency proceedings.

Erika is also active in the firm’s pro bono efforts, including representing clients in unemployment benefits appeals and in obtaining restraining orders for survivors of domestic violence.

Before joining the firm, Erika gained experience at a national litigation firm, where she worked on construction and real estate matters. She earned her J.D. from Northeastern University School of Law, where she was a member of the Black Law Students Association and participated in moot court.

Education
  • Northeastern University School of Law (J.D.)
  • Stonehill College (B.A., magna cum laude)
    • Lambda Epsilon Sigma Honor Society, President
    • Presidential Merit Scholar
Bar & Court Admissions
  • Massachusetts
  • U.S. District Court, District of Massachusetts
  • U.S. Court of Appeals for the First Circuit
Professional Qualifications
  • Boston Bar Association
Viewpoints
All Viewpoints
SEC Establishes Retail Fraud Working Group to Combat Fraud Targeting Everyday Investors
The U.S. Securities and Exchange Commission (“SEC”) announced on July 7, 2026, the creation of the Retail Fraud Working Group, a new initiative within the Division of Enforcement designed to identify and combat fraud targeting main street investors. The announcement formalizes a priority that SEC Enforcement Director David Woodcock previewed in his May 13, 2026, remarks to the Managed Funds Association Legal & Compliance Conference, reflecting the current Commission’s broader back-to-basics enforcement posture. For issuers, broker-dealers, investment advisers, and private fund managers with retail exposure, the announcement signals that retail-facing enforcement will be a sustained focus of the Division’s work in the months and years ahead. Overview The Retail Fraud Working Group will leverage staff and resources across the Commission to identify fraud and other misconduct targeting retail investors, including offering frauds, pump-and-dump schemes, market manipulation, and breaches of duties owed to customers by investment advisers and broker-dealers. The Group’s initiative is threefold: (i) to serve as a dedicated resource to proactively generate cases; (ii) to work with the Commission’s domestic regulatory partners and foreign counterparts; and (iii) to assist with educating retail investors in coordination with the SEC’s Office of Investor Education and Assistance. The Group will be led by Kate Zoladz, Deputy Director, West, and Kim Frederick, Assistant Director of the Asset Management Unit. Ms. Frederick’s role in the Asset Management Unit suggests that adviser and private fund conduct affecting retail investors will be a focus area for the Group. Chairman Paul S. Atkins described the initiative as “a return to the core values and principles of the enforcement program,” and Director Woodcock emphasized the Group’s role in “generating cases, building partnerships with our regulatory counterparts, and using data and technology to find and stop those who seek to take advantage of retail investors.” About Our Small-Firm Task Force Sullivan & Worcester’s Small-Firm Task Force is actively engaged in advising clients on the implications of the Retail Fraud Working Group and can assist with responding to any related SEC inquiries. The Task Force unites the firm’s Capital Markets, Regulatory Compliance, Government Investigations, and Financial Services Litigation practices, each with deep experience advising issuers, broker-dealers, investment funds, and institutional investors in the small-cap, micro-cap, and mid-market segments. Our interdisciplinary team is well-positioned to help clients navigate the SEC’s renewed retail-fraud enforcement priorities and to develop practical, risk-based compliance strategies aligned with the current regulatory environment.
FINRA’s Small-Cap Sweep: Strategic Steps for Broker-Dealers
It has been approximately one (1) month since the Financial Industry Regulatory Authority (FINRA) has launched a targeted review of broker-dealer activity in small-capitalization offerings involving foreign issuers—particularly those with operations in foreign jurisdictions such as China. The scope of the review extends across both public and private offerings of small-cap exchange-listed issuers and applies to firms that have acted as underwriters, bookrunners, syndicate or selling-group members, placement agents, or engaged in follow-on trading or omnibus account activity. For broker-dealers active in this market segment between January 1, 2023, and September 30, 2025, this initiative warrants immediate attention. FINRA’s focus underscores the need for firms to proactively strengthen compliance, supervisory and due-diligence frameworks before scrutiny is initiated. Implications for Broker-Dealers For broker-dealers that have acted in offerings of foreign-issuer small-cap companies, or engaged in corresponding trading, the risk of regulatory inquiry is now heightened. Firms should assume that FINRA may request detailed documentation of supervisory procedures, training materials, due-diligence records, compensation arrangements, and transaction lists. Potential exposure encompasses both the underwriting/placement side and the secondary trading side, particularly where omnibus accounts or affiliate-linked trading have occurred. Moreover, compliance weaknesses in this area may expose firms to broader regulatory focus given FINRA’s emphasis on market integrity and manipulative trading risks in small-cap IPOs. As a result, firms should view this not simply as a matter of historical transactions but as an active compliance priority for present-day operations and future offerings. Strategic Compliance Priorities and Action Plan Broker-dealers should undertake an immediate, firm-wide review of their involvement in relevant small-cap foreign-issuer offerings. This review should begin with an inventory of all transactions, public or private, in which the firm acted as underwriter, bookrunner, syndicate or selling-group member, placement agent, or participated in secondary trading during the relevant period. Firms should review whether their written supervisory procedures (WSPs), compliance manuals, training materials and internal guidance adequately address the risks particular to small-cap foreign-issuer offerings. This includes controls around due diligence of issuers, audit-firm and management backgrounds, beneficial-owner structures, cross-border legal/regulatory risks, syndicate compensation, and trading after the offering. Surveillance systems and trading desk controls should similarly be assessed to ensure they capture unusual trading patterns consistent with manipulative or coordinated activity. Firms should evaluate whether their AML/KYC programs are appropriately scaled to the enhanced risk of foreign issuers and thinly-traded securities, and whether their vendor-risk frameworks adequately cover third-party trading platforms, omnibus accounts, and algorithmic or remote trading tools. From a governance standpoint, senior management, compliance heads and the board should elevate this matter within their risk-assessment frameworks. Firms should consider whether internal audit scopes and independent reviews cover this business line, whether incentives or compensation structures may have encouraged participation in higher-risk offerings, and whether escalation procedures are clearly defined and monitored. Finally, firms should prepare for regulatory engagement by gathering and organizing deal files, training logs, supervisory review documentation, compensation records and transaction lists now, rather than waiting until a request arrives. Key Takeaways The targeted review by FINRA of small-cap foreign-issuer offerings signals a clear regulatory priority and a call to broker-dealers to raise their vigilance. For firms with exposure in this area, now is the time to act. Waiting until after a request is received may leave a firm scrambling and vulnerable to findings of deficient controls or documentation. The themes underpinning the review—cross-border risk, thin-traded securities, manipulative activity, and weak controls—are broader than the specific focus and should prompt firms to proactively enhance controls across the board. Senior leadership should not view this as a niche compliance issue, but rather as a signal of elevated scrutiny across multiple lines of business. With proper preparation, firms can not only respond to potential regulatory requests but demonstrate a thoughtful, forward-looking compliance program aligned with the evolving risk landscape.
Sullivan Files Amicus Brief on Behalf of NAIOP Massachusetts
Sullivan was pleased to file an amicus brief on behalf of NAIOP Massachusetts – The Commercial Real Estate Development Association (NAIOP) in the case of Attorney General v. Town of Milton. The case involves the Town’s failure to comply with Section 3A of the Zoning Act (otherwise known as the MBTA Communities Law). The brief addresses the issue of whether or not Section 3A provides the sole remedy for noncompliance, and whether, and to what extent, the Attorney General’s office is authorized and has standing to enforce compliance. The brief urges the Supreme Judicial Court to affirm that the Attorney General may elect to enforce the MBTA Communities Law through requests for declaratory and injunctive remedies. “Excessive discretion in local zoning is a significant barrier to housing production. The legislature recognized this by imposing a requirement for MBTA communities to adopt zoning that permits multi-family zoning as-of-right,” said Gregory Sampson, leader of the firm’s Permitting & Land Use practice group. “Communities cannot be allowed to ignore this requirement if we hope to address our housing issues. The enforcement of the MBTA Communities Law is a matter of public interest and, therefore, it is NAIOP’s belief that it is within the authority of the Attorney General to pursue enforcement of the law.” The brief was written by a Sullivan team consisting of Gregory Sampson, Victor Baltera, Natasha Varyani, and Erika Dennery. The full text of the brief can be found here.
Sullivan & Worcester Welcomes 2023 First-Year Associates
Sullivan has welcomed its 2023 First-Year Associates to the firm. The associates join Sullivan after having completed the firm's summer associate program, as well as various clerkships and internships. The lawyers will be located in our Boston office. Erika Dennery Erika received her J.D. from Northeastern University, where she was a member of the Black Law Students Association. While at Northeastern, Erika competed in the 46th Annual Robert F. Wagner National Labor and Employment Law Moot Court Competition, where she wrote a brief and argued on behalf of an employee for a Title VII hostile work environment claim. Erika's experience includes working as an intern at the United States Department of Homeland Security and as a legal intern at Prisoners Legal Services of Massachusetts, where she advocated for the healthcare and constitutional rights of indigent clients. Most recently, Erika worked as a law clerk at MG+M The Law Firm, a national litigation firm, where she worked on cases involving general commercial matters, construction and real estate. Shannon Moore Shannon is a first-year associate in Sullivan’s Boston office. She earned her J.D. from the University of Notre Dame, where she was the Executive Articles Editor for the Journal of Law, Ethics & Public Policy and the brief writer for the Moot Court Board’s Intellectual Property Team. She was also member of the St. Thomas More Society, the Federalist Society and the First-Generation Professional Students Organization. While in law school, Shannon worked as an Academic Strategy Tutor for members of the Notre Dame Football Team. Shannon began at Sullivan as a summer associate in 2022. Prior to that, she was a District Court judicial intern for the Honorable Judge Trevor N. McFadden in Washington, DC. Joshua Stein Josh earned his J.D. from the Boston University School of Law, where he was a staff member on the Review of Banking and Financial Law, treasurer of the Jewish Law Students Association, a member of the Business Law Society and a participant in the ABA Negotiation Competition. Additionally, Josh served as a research assistant for Professor Marni Caputo. Previously, Josh was a legal intern for the Massachusetts Securities Division. Prior to law school, Josh worked for Thrivent Financial as a financial advisor and analyst. Josh is also an active volunteer with the Orphaned Starfish Foundation, a 501(c)(3) non-profit organization focused on developing vocational centers for orphans, victims of abuse and at-risk youth. Gabrielle Strasser Gabrielle earned her J.D. from the Boston University School of Law, where she was on the International Law Journal. While at BU Law, Gabrielle was the president of the Communications, Entertainment, and Sports Law Association, as well as a member of the Women’s Law Association and Intellectual Property Law Society. Prior to attending law school, Gabrielle worked as a 7th grade science teacher in the Chelsea Public School District in Massachusetts. Additionally, she piloted a climate change resilience after-school program in the school district and did curriculum development with the New England Aquarium. She was also a Corps Member for Teach for America, and most recently, a legal assistant at the Boston University Civil Litigation and Justice Program, where she managed a 10-person caseload. Alison Strongwater Ali earned her J.D. from the New York University School of Law. There, she was an Institute for International Law and Justice Joyce Lowinson Scholar, as well as an articles editor for the Journal of International Law, and a member of the International Law Society and Law Women. In addition, she served as a research consultant for a boutique cybersecurity firm. Prior to law school, Ali worked for Teach for China, and she was a summer legal fellow for Just Security, where she published three articles on various submissions regarding domestic terrorism and cybersecurity.