Blake Osborn

Blake Osborn

Orrick, Herrington & Sutcliffe LLP

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The SEC Criticizes One of Its Own

Even with the SEC’s home-court advantage in bringing enforcement actions in its administrative court rather than in federal court, the SEC will still criticize its own administrative law judges (“ALJ”) when an ALJ’s decision...more

5/6/2015 - Article III Broker-Dealer Municipal Securities Market Ponzi Scheme Popular SEC

Additional Avenues May Be Available for Federal Regulators to Curtail Deceptive Practices in High Frequency Trading

We first heard about the SEC’s increased focus on high-frequency trading in June 2014 when the SEC announced its desire to promulgate new rules on high frequency trading to address the lack of transparency in dark pools and...more

2/18/2015 - Commodities Exchange Act Dark Pool Disruptive Trading Practices Front-Running High Frequency Trading Pinging SEC Strategic Enforcement Plan

For Now, The Broad Interpretation of “Foreign Officials” Under the FCPA Is Here to Stay

In recent years, the DOJ and SEC have significantly increased their Foreign Corrupt Practices Act (FCPA) enforcement efforts, and in the process, have successfully advocated the theory that state-owned or state-controlled...more

10/20/2014 - Compliance DOJ Enforcement Enforcement Actions FCPA Foreign Official SEC

Assessing the Increased Regulatory Focus on Public Company Internal Control and Reporting

Over the past few months, the Securities and Exchange Commission (‘‘SEC’’) has publicly stated its increasing focus on public company internal controls and related reporting obligations. In February of this year at the...more

10/9/2014 - Bank Secrecy Act Banking Sector Banks Corporate Management Financial Institutions FinCEN FINRA ICFR Internal Audit Functions Internal Controls Publicly-Traded Companies Reporting Requirements SEC Strategic Enforcement Plan U.S. Treasury

Flash Rules: Is A Wall Street Reform on the Horizon or is the SEC Merely Reacting to the Latest Media Headline?

Michael Lewis’ new book Flash Boys: A Wall Street Revolt has caused a commotion on Wall Street, on Capitol Hill, and with law enforcement agencies. The SEC is the latest government agency to examine and propose new rules on...more

6/18/2014 - Administrative Hearings Alternative Trading Systems Dark Pool Financial Regulatory Reform FINRA High Frequency Trading Liquidnet Proposed Regulation SEC Securities Exchange Act Wall Street

Are Confidential Witness Reforms Looming On The Horizon? Can The Plaintiff’s Bar Stop Them?

A decision is expected shortly in the highly publicized so-called confidential witness “scandal” involving the Robbins Geller Rudman & Dowd law firm. Judge Suzanne B. Conlon of the United States District Court, Northern...more

1/23/2014 - Confidential Witnesses Evidence Rule 11 Witness

Lookout For The SEC: After First Demanding More Admissions, The SEC Is Additionally Increasing Monetary Penalties And Giving...

After first announcing a change on June 18 of this year to demand more admissions in SEC actions, an SEC leader recently made further comments echoing that same sentiment, as well as referencing the SEC’s intended use of...more

10/8/2013 - Citigroup Civil Monetary Penalty SEC Settlement

Here’s Looking At You, Money Market Funds

While money market funds did not exist when Humphrey Bogart spoke his famous line in Casablanca, since the 2008 financial crisis, reforming money market funds have been the subject of high drama and intense scrutiny on...more

6/11/2013

Stop! In The Name Of ... 28 U.S.C. §2462

On January 8, 2013, the U.S. Supreme Court heard arguments in Gabelli v. Securities and Exchange Commission, No. 11-1274, concerning when the clock begins to run on the five-year statute of limitations for civil penalty...more

1/15/2013 - Civil Monetary Penalty Enforcement Actions Gabelli v SEC Penalties SCOTUS SEC Securities Statute of Limitations

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