In the United States Court of Appeals For the Second Circuit ________

AUGUST TERM 2021

ARGUED: JANUARY 19, 2022 DECIDED: MARCH 13, 2024

No. 20-4080-cv

SECURITIES AND EXCHANGE COMMISSION,

Plaintiff-Appellee,

v.

MOHAMMED ALI RASHID,

Defendant-Appellant. ________

Appeal from the United States District Court for the Southern District of New York. ________ Before: KEARSE, WALKER, AND SULLIVAN, Circuit Judges. ________

This appeal arises from a Securities & Exchange Commission enforcement action brought against Defendant-Appellant Mohammed Ali Rashid, a former employee of private equity firm Apollo Management L.P. Rashid was accused of breaching his fiduciary duties to the Apollo-affiliated private equity funds he