Pay-to-Play: Recent SEC Actions Highlight Importance of Compliance Controls


I. Overview - Two recent actions by the U.S. Securities and Exchange Commission (“SEC”) and its staff highlight the importance of compliance controls with respect to political contributions and other political activities. In a settled enforcement action, the SEC alleged that a prominent municipal securities dealer (“Municipal Dealer”) violated the Municipal Securities Rulemaking Board’s (“MSRB”) Rule G-37 (“Rule G-37” or “Rule”) after an employee made certain, undisclosed, “in-kind” campaign contributions (“Settlement Order”).

The “contributions” included using the firm’s resources during work hours to engage in campaign activity in breach of the firm’s policies. According to the SEC, the enforcement action is the first for pay-to-play violations involving “in-kind” campaign contributions. The Settlement Order also announces a heightened compliance obligation applicable to employees known to have been politically active.

Please see full alert below for more information.

LOADING PDF: If there are any problems, click here to download the file.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

© Dechert LLP | Attorney Advertising

Written by:


Dechert LLP on:

Readers' Choice 2017
Reporters on Deadline

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:

Sign up to create your digest using LinkedIn*

*By using the service, you signify your acceptance of JD Supra's Privacy Policy.

Already signed up? Log in here

*With LinkedIn, you don't need to create a separate login to manage your free JD Supra account, and we can make suggestions based on your needs and interests. We will not post anything on LinkedIn in your name. Or, sign up using your email address.