News & Analysis as of

Enforcement Enforcement Actions Risk Management

Venable LLP

Crystal Clear: New Guide on Third-Party Risk Management for Community Banks - and Others

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It is no secret that the Federal Reserve, the FDIC, and the OCC have zeroed in on banks' use of third parties for products, services, and other operations, the risks those arrangements may pose, and banks' responsibility to...more

Benesch

Annual Report to Congress on Breaches of Unsecured Protected Health Information

Benesch on

The U.S. Department of Health and Human Services (HHS), Office for Civil Rights (OCR) recently published an executive summary (Report) outlining key enforcement activities of the Health Insurance Portability and...more

Harris Beach PLLC

HHS Office of Inspector General July 2023 Enforcement Activity

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Harris Beach invites you to register for its 7 Element compliance program series addressing New York’s 2020 and 2022 updates to Medicaid Compliance Program requirements. Starting on August 16th, each live program will be no...more

Latham & Watkins LLP

High GDPR Fines: German Data Protection Authority Joins the Club

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Following in the footsteps of the CNIL and the ICO, the Berlin DPA will impose a multimillion-euro fine for breach of the GDPR. The Berlin Data Protection Authority (Berlin DPA) recently announced that it will issue a...more

King & Spalding

Our Modern Markets: SEC Enforcement Focuses On Market Structure In Response To Rapidly-Changing Equity Markets

King & Spalding on

On Monday, November 2, 2015, Andrew Ceresney, Director of the SEC’s Division of Enforcement, gave a speech at the SIFMA Compliance & Legal Society New York Regional Seminar in which he sought to address what he views as the...more

Robins Kaplan LLP

[Webinar] Managing Risk in the Era of Cyber Insecurity - Oct. 27th, 1:00 CST

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Join privacy and data security attorney Richard Martinez for this informative session that will break down the details of the 50 leading enforcement actions taken by the FTC to regulate data privacy and cyber security. By...more

Foley & Lardner LLP

A Compilation of Enforcement and Non-Enforcement Actions

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Non-Enforcement - Form PF — What Purpose? SEC registered investment advisers with at least $150 million of assets under management in private funds are required to periodically file Form PF with the SEC. The...more

Manatt, Phelps & Phillips, LLP

AML Compliance Expectations Unabated—Fines, Enforcement Actions and a Deferred Prosecution Agreement Against Banks, Money...

Why it matters - Three Financial Crimes Enforcement Network (FinCEN) orders, three sets of fines and asset forfeitures, a deferred prosecution agreement and one bank enforcement action demonstrate the resolve of the...more

Robins Kaplan LLP

[Webinar] Transparency after a Compliance Failure: Managing the Risk or Maximizing the Opportunity? - June 16, 1:00 CDT

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Every week we read about an organization facing the question of how to respond to a compliance or ethics mistake that has become public. Not so public are the discussions in the background: Should information be shared? If...more

Katten Muchin Rosenman LLP

Corporate and Financial Weekly Digest - Volume IX, Issue 39

In this issse: - ISS Publishes Results of Annual Global Voting Policy Survey - FINRA Requests Comment on a Rule Proposal to Implement the Comprehensive Automated Risk Data System - NFA Issues Notice...more

Sheppard Mullin Richter & Hampton LLP

Second Circuit Overturns District Court’s Rejection of SEC-Citigroup Fraud Settlement

In a closely-watched decision involving judicial review of agency settlements, the Unites States Court of Appeals for the Second Circuit vacated United States District Court Judge Jed Rakoff’s 2011 order rejecting a proposed...more

Dechert LLP

Second Circuit Overturns Lower Court's Refusal to Approve SEC Settlement With Citigroup

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In an eagerly anticipated decision, the U.S. Court of Appeals for the Second Circuit vacated the 2011 decision of Judge Jed S. Rakoff of the U.S. District Court for the Southern District of New York, rejecting a proposed...more

Burr & Forman

Second Circuit Reverses SDNY In SEC-Citigroup Settlement Case

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On June 4, 2014, the United States Court of Appeals for the Second Circuit vacated and remanded a November 28, 2011 order from the United States District Court for the Southern District of New York refusing to approve a...more

Robins Kaplan LLP

Second Circuit Says Wall Street Can Play “Truth or Settle”

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On June 4, 2014, a three-judge Second Circuit panel reversed and remanded Judge Rakoff’s 2011 order that rejected an S.E.C. settlement with Citigroup. The proposed settlement resolved the S.E.C.’s securities fraud case...more

Mintz - Securities & Capital Markets...

Second Circuit’s Citigroup Decision Protects SEC’s Discretion in Settling Enforcement Cases

Wednesday’s decision by the U.S. Court of Appeals for the Second Circuit in the Citigroup case is significant because it clarifies the standards for judicial review of consent decrees in SEC enforcement proceedings and...more

Dorsey & Whitney LLP

This Week In Securities Litigation (Week ending June 6, 2014)

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The SEC had mixed results in court this week. A Manhattan jury returned a verdict against the agency in a high profile and long-running insider trading case where the agency had previously obtained favorable rulings from the...more

Burr & Forman

Trials Are About Truth; Consent Decrees Are About Pragmatism

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I recently wrote about Judge Rakoff’s refusal to enter the SEC’s proposed consent decree in SEC v. Citigroup Global Markets, Inc., 827 F. Supp. 2d 328 (SDNY 2011) – and the shift in SEC enforcement policy that it prompted. ...more

Brooks Pierce

Judge Rakoff Reversed by Second Circuit on SEC-Citi case, Still Sort of Wins

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You’d be forgiven if you’d forgotten at this point, but way back in Obama’s first term, the SEC once investigated and sued Citigroup for its involvement in a collateralized debt obligation deal. As the SEC said in its...more

Bennett Jones LLP

Judge Rakoff Overturned: SEC-Citigroup Settlement Sent Back for Reconsideration

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In a long-awaited decision, the United States Court of Appeals for the Second Circuit today overturned Judge Rakoff's highly controversial decision which refused to approve a $285-million settlement between the United States...more

Bracewell LLP

Second Circuit Says District Court Erred In Blocking SEC/Citigroup Settlement

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The United States Court of Appeals for the Second Circuit yesterday vacated a closely-watched 2011 decision by U.S. District Court Judge Jed Rakoff rejecting a $285 million fraud settlement between Citigroup Inc. and the U.S....more

Dorsey & Whitney LLP

Consent Decrees, the District Court and the SEC: The Citigroup Decision

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The Second Circuit handed down its long awaited opinion in SEC v. Citigroup Global Markets, Inc., Nos. 11-5227-cv, 11-5375-cv and 11-5242-cv (2nd Cir. June 4, 2014). The decision arises out of the refusal of the District...more

Dechert LLP

BNA's Banking Report: Enforcement 2013: Enforcement Actions Continue Three-Year Decline; DOJ Emerges as Major Player

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Overall Trends & Outlook - From an enforcement standpoint, 2013 was another historic year in a number of important ways beyond the sheer number of cases, which were again significant. Federal banking agencies1 issued...more

Dechert LLP

SEC Charges an Investment Adviser and a Portfolio Manager with Fraud and Causing a Money Market Fund to Violate Rule 2a-7

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This OnPoint describes the role of the SEC’s Division of Investment Management (Division) in uncovering the alleged fraud through an analytical review of the Fund’s performance data and portfolio information. It then...more

The Volkov Law Group

Congressional Investigations: Unique And Significant Risks

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We have all watched the familiar scene on Capitol Hill – the latest public scandal like officials from the Internal Revenue Service are dragged up to Capitol Hill to appear before a Committee, raise their right hands, take...more

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