Public pension trustees are fiduciaries. That means they are required to evaluate not just performance, but governance, integrity, compliance culture, and reputational risk. When it comes to Apollo Global Management, the pattern is no longer deniable. This is not about one headline. It is about two decades of recurring conduct. An article in Pensions & Investments says two major pensions, California Teachers’ and Connecticut, are looking at Apollo, and dozens more should be looked at.
Public Pensions have looked the other way at SEC violations, the very agency designed to protect them. So, at the most broad level, pensions should be divesting from Apollo based on their role as an investment manager. In 2016, the Securities and Exchange Commission fined Apollo $52.7 million for failing to disclose accelerated monitoring fees and conflicts of interest to fund investors. The SEC concluded Apollo misled investors regarding fee practices — one of the largest penalties of its type at the time. Then came the Epstein revelations. In 2021, Apollo disclosed to the SEC that Leon Black had paid Jeffrey Epstein approximately $158 million for purported “professional services.” A Dechert investigation letter stated Apollo itself “did no business” with Epstein and that no other employees engaged him. In 2025, the SEC ordered Apollo to pay $8.5 million for recordkeeping violations. But that 2021 explanation and SEC disclosure did not hold up under the most recent release of the Epstein Files In 2026, the AFT and AAUP formally urged the SEC to investigate Apollo’s 2021 disclosures, citing newly released Epstein files and alleging investor communications may present an “inaccurate and incomplete picture.”
Apollo manages dozens of underlying portfolio companies within their Private Equity Parents nationwide have been horrified that accused pedophile Leon Black had access to millions of children’s photos through their company Lifetouch. Dozens of other Apollo portfolio companies have been fined by numerous Federal Agencies (Source Violation Tracker Database).
The penalties include:
- $210 million – America Online (accounting fraud)
- $191 million – Apollo Education (FTC consumer protection)
- $125 million – Kindred Healthcare (False Claims Act)
- $117 million – Yahoo (privacy violations)
- $104 million – Vencor/Ventas (False Claims Act)
- $45 million – Athene (insurance violations, NY-DFS)
- Numerous additional DOJ, SEC, EPA, FTC, and state attorney general actions
The 2019 Divestment Debate Should Be Reopened
In 2019, multiple public pensions considered divesting Apollo following the Epstein revelations. They ultimately declined after assurances that the matter was personal and resolved.
But since then, New Epstein documents have surfaced. Pension stakeholders have called for renewed SEC investigation. Additional regulatory actions have occurred.
Plans need to consider Divestment.
https://www.sec.gov/Archives/edgar/data/1411494/000119312521016405/d118102d8k.htm SEC Dechert Letter
The CommonSense 401k Project 