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Second Circuit Reinforces FCPA’s Jurisdictional Limits

Ruling holds that the government cannot use conspiracy and accomplice liability theories to reach foreign nationals that lack US ties. Key Points: ..Non-resident foreign nationals who are not otherwise subject to direct...more

Supreme Court: SEC ALJs Are Officers Subject to Constitution’s Appointments Clause

Respondents in pending or future proceedings should carefully assess their options until several key legal questions are resolved. The United States Supreme Court recently issued its ruling in Lucia v. Securities and...more

The Circuits Are Split: Are Tangible Benefits Required for Insider Trading Liability?

The Ninth Circuit’s recent decision calls into question the Second Circuit’s definition of “personal benefit” for insider trading liability in criminal prosecutions. On July 6, 2015, United States District Court Judge...more

Expanding FIRREA Liability for Financial Institutions: Recent Second Circuit Developments

In a brief — and swiftly decided — per curiam decision issued June 4, 2015, the US Court of Appeals for the Second Circuit affirmed the wire fraud and wire fraud conspiracy convictions of three former UBS Financial Services,...more

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