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2014 Insider Trading Annual Review

Overview of Insider Training Law - “Insider trading” is an ambiguous and overinclusive term. Trading by insiders includes both legal and illegal conduct. The legal version occurs when certain corporate insiders –...more

Insider Trading Annual Review - 2013

Looking Back - 2013 witnessed several long-anticipated developments in the world of insider trading, punctuating another year of aggressive enforcement in the United States and abroad. After years of pursuit, the...more

FINRA Continues its Crackdown on Companies that Fail to Respond to Red Flags

FINRA continues to discipline broker-dealers that fail to detect and investigate so-called “red flags” of suspicious account activity. Yesterday, FINRA announced a $1 million fine against COR Clearing LLC (the “Firm”) –...more

The Second Circuit Speaks: The Presumption Against Extraterritoriality Applies to Criminal Prosecutions

Last Friday, the Second Circuit held that the presumption against extraterritoriality applies to criminal cases, resolving a key question left open by the United States Supreme Court in Morrison v. National Australia Bank,...more

FINRA Increases the Cost of Penny Stock-Related AML Deficiencies

The price tag for failing to detect suspicious activity in penny stocks through an adequate anti-money laundering program continues to increase. Oppenheimer & Co., Inc. recently agreed to pay FINRA more than $1.4 million to...more

FINRA Focuses on Anti-Money Laundering Procedures and Red Flags

Last week, the Financial Industry Regulatory Authority (FINRA) publicized penalties against three companies – as well as four associated individuals – that it found had failed to establish and implement adequate procedures...more

What Does Cooperation Buy You?

Cooperation. The word is filled with meaning for enforcement professionals. The U.S. Securities and Exchange Commission and the U.S. Department of Justice profess to weigh it heavily when making charging and sanctioning...more

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