Kristen Bartlett

Kristen Bartlett

Orrick, Herrington & Sutcliffe LLP

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International Hacking and Insider Trading Scheme Exposes Cybersecurity Vulnerabilities at Third-Party Vendors

On August 11, 2015, the SEC announced that it was bringing fraud charges against 32 defendants for their alleged participation in a five-year, international hacking and insider trading scheme. According to the SEC, two...more

8/19/2015 - Criminal Prosecution Cyber Attacks Cyber Crimes Cybersecurity Cyprus Data Protection Data Security Financial Markets FINRA France Hackers Insider Trading Non-Public Information Popular Russia SEC Third-Party Service Provider Ukraine

One Step Forward and One Step Back: Southern District of New York Denies Motion to Enjoin SEC’s Administrative Proceedings,...

Last week, the SEC scored a victory in its battle to defend the use of administrative proceedings in enforcement actions seeking penalties against unregulated entities or persons. On June 30, 2015, Southern District of New...more

7/7/2015 - ALJ Appointments Clause Breach of Duty Discovery Dodd-Frank Enforcement Actions Fiduciary Duty Financial Statements SEC

Remote Tippees Beware: Even if the DOJ Can’t Reach You After Newman, The SEC Can

The fall-out from the Second Circuit’s decision in U.S. v. Newman continued last week in SEC v. Payton, when Southern District of New York Judge Jed S. Rakoff denied a motion to dismiss an SEC civil enforcement action against...more

4/15/2015 - Brokers Criminal Prosecution DOJ Enforcement Actions Illegal Tipping Insider Trading Judge Rakoff Material Nonpublic Information Misappropriation Personal Benefit SEC US v Newman

Out Of Control: SEC Says Lack Of Internal Controls Led To HP Paying More Than $108 Million To Settle FCPA Actions

On April 9, 2014, the Securities and Exchange Commission announced that Hewlett-Packard had agreed to pay more than $108 million to settle Foreign Corrupt Practices Act actions brought by the SEC and the Department of...more

4/16/2014 - FCPA Hewlett-Packard SEC Settlement

Time Is Money: Second Circuit Vacates SEC’s $38 Million Fine Against Hedge Fund Pentagon Capital Management

On August 8, 2013, the Second Circuit vacated the SEC’s $38 million fine against hedge fund Pentagon Capital Management PLC, holding that the Supreme Court’s decision in Gabelli v. SEC required the case to be remanded for...more

8/13/2013 - Capital Markets Civil Monetary Penalty Fines Hedge Funds Rule 10b-5 SEC Securities Act of 1933

President Barack Obama’s Win Also a Win for the SEC and the CFTC

The U.S. Securities and Exchange Commission (“SEC”) and the Commodity Futures Trading Commission (“CFTC”) can breathe a little easier after President Barak Obama’s re-election on Tuesday, November 6, 2012, according to legal...more

11/14/2012 - Barack Obama CFTC Dodd-Frank SEC

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