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Foley Hoag LLP - White Collar Law &...

SEC to Continue Aggressive Enforcement Efforts in 2024 After Record-Setting 2023

This is the fourth in our 2024 Year in Preview series examining important trends in white collar law and investigations in the coming year. We will be posting further installments in the series throughout the next several...more

Foley & Lardner LLP

What Every Multinational Company Needs to Know About...Implementing an International Compliance Program (Part III)

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We have received several requests for a list of the compliance policies that make sense for every multinational company. So, as a follow-up to our earlier two posts providing “twelve steps to international compliance” (see...more

Snell & Wilmer

Corporate Communicator - 2024 Annual Meeting Season

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Clawback Rules. As previously discussed in last Winter’s Corporate Communicator, the Securities and Exchange Commission (“SEC") adopted final rules in October 2022 directing the NYSE and Nasdaq to adopt listing standards that...more

Perkins Coie

Preparing for the 2024 Public Company Reporting Season

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In anticipation of the upcoming reporting season, this Update highlights some of the most significant rule changes, guidance, institutional investor areas of focus, and trends for public companies to consider in preparing...more

Perkins Coie

Securities Enforcement Forum West 2022: SEC Affirms Aggressive Approach

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On May 12, 2022, senior Division of Enforcement officials from the U.S. Securities and Exchange Commission (SEC) shared the stage with SEC alumni, private practitioners, and other professionals in the field at the Securities...more

Cooley LLP

Blog: Early SEC Enforcement Trends from Chairman Gary Gensler’s First 100 Days

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Gary Gensler was sworn in as chair of the Securities and Exchange Commission on April 17, 2021. Chairman Gensler has promised to strengthen transparency and accountability in the financial markets. Under Chairman Gensler, we...more

Kramer Levin Naftalis & Frankel LLP

The SEC’s Continued Focus on Cybersecurity Enforcement

On June 14, the Securities and Exchange Commission (SEC) announced a $490,000 settlement with the real estate services provider First American Financial Corporation (First American) for violations of disclosure controls and...more

Morgan Lewis

Spotting and Mitigating Enforcement Issues Concerning Cybersecurity-Related Controls and Disclosures

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The growing frequency and public awareness of cyberincidents, evolution of technologies employed by intruders, and proliferation of personal data and infrastructure vulnerable to attack have all contributed to heightened...more

Fenwick & West LLP

“Business as Usual” as Securities Enforcement Leaders Gather Virtually for Securities Enforcement Forum West 2020

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Like most of the rest of the world, the speakers and attendees at Securities Enforcement Forum West 2020 last week had to adapt this year by trading in their microphones on the stage of a grand ballroom for an array of home...more

ArentFox Schiff

Investigations Newsletter: Whistleblower Collects on Cybersecurity FCA Case

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Whistleblower Collects on Cybersecurity FCA Case - On July 31, 2019, Cisco Systems agreed to pay $8.6 million in civil damages to settle claims that it sold video surveillance technology with known security flaws to several...more

Patterson Belknap Webb & Tyler LLP

SEC Cyber Briefing: Investigation into Wire Fraud and a Look at 2019 Regulatory Initiatives

In our final installment of a three-part series, we look at the U.S. Securities and Exchange Commission’s Investigative Report into the epidemic of wire fraud or “business email compromise,” and then, based on its 2018...more

Patterson Belknap Webb & Tyler LLP

SEC Cyber Briefing: Regulatory Expectations for 2019

Cybersecurity has played an important role in the U.S. Securities and Exchange Commission’s regulatory agenda during the past year. And it’s likely to become even more important in 2019....more

Moore & Van Allen PLLC

SEC Issues Disclosure Guidance as Part of Continued Focus on Cybersecurity

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As cybersecurity attacks have continued to gain prominence as a threat posing critical risk management and compliance challenges for financial institutions, the Securities and Exchange Commission (SEC) has emerged as an...more

Jones Day

The Perils of Well-Intentioned Deception: Insider Trading Case Highlights Challenges Facing Public Companies

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The Situation: Despite Equifax's use of a cover story to keep employees from learning it was the victim of a serious data breach, a then-employee allegedly figured it out and made illegal securities trades based on the...more

Sheppard Mullin Richter & Hampton LLP

You Might Be an Inside Trader If…You Trade on Your Unconfirmed Suspicions of a Cybersecurity Event Prior to Its Public Revelation...

Earlier this year, the SEC released cybersecurity guidance addressing, among other things, the risk of insider trading in the event of a data breach. This risk comes in multiple forms, including the intruders trading on...more

Parker Poe Adams & Bernstein LLP

Don’t Overlook the SEC’s Cybersecurity Governance Guidance

In late February, the SEC approved what it labeled “Guidance on Public Company Cybersecurity Disclosures.” And, sure enough, about three-quarters of its 24 pages focus on the various categories and locations of cybersecurity...more

Manatt, Phelps & Phillips, LLP

Equifax Insider Trading Charges Highlight Importance of Tailored Policies and Controls

In what appears to be the first insider trading case stemming from insider knowledge of material nonpublic cyber-related information, the Securities and Exchange Commission brought civil charges against a former Equifax...more

Akin Gump Strauss Hauer & Feld LLP

Big Data and the Risks of Insider Trading

In the perennial quest for alpha, investment managers have turned increasingly to big and alternative data for market insights. The most prominent consumers of this data on Wall Street are managers of ‘‘quant’’ funds, which...more

Cooley LLP

Alert: SEC Issues New Guidance on Cybersecurity Disclosure and Policies

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In February, the SEC announced that it had adopted long-awaited new guidance on cybersecurity disclosure. While the new guidance builds on Corp Fin's 2011 guidance on this topic, it carries more weight because it bears the...more

Orrick, Herrington & Sutcliffe LLP

SEC Commissioners Provide Guidance on Cybersecurity Disclosures After Wave of Record Incidents

The Commission's "new" cybersecurity guidance largely rehashes existing guidance, as is highlighted by objections from two commissioners. At most, the additional qualitative guidance is incremental. It reiterates the need to...more

Eversheds Sutherland (US) LLP

The SEC wants companies to talk about cybersecurity

On February 21, 2018, the Securities and Exchange Commission issued an interpretive release1 providing important guidance to certain registrants on cybersecurity disclosure. Coming on the heels of dozens of high-profile...more

Balch & Bingham LLP

SEC Releases Guidance on Disclosures Concerning Cybersecurity Matters

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On February 21, 2018, the Securities and Exchange Commission (SEC) published a release entitled “Commission Statement and Guidance on Public Company Cybersecurity Disclosures” (“Release”). Designed to assist public companies...more

Stinson - Corporate & Securities Law Blog

SEC Cybersecurity Disclosure and Controls Checklist

In February 2018 the SEC outlined its views with respect to cybersecurity disclosure requirements under the federal securities laws as they apply to public reporting companies. Set forth below is a checklist of items included...more

Fenwick & West LLP

SEC Releases Updated Cybersecurity Guidance

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The U.S. Securities and Exchange Commission on Feb. 21, 2018, issued interpretive guidance on public company cybersecurity disclosures. The new guidance will affect public companies and companies seeking to go public in...more

McGuireWoods LLP

New SEC Cybersecurity Guidance Outlines Disclosure Obligations

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Last week, as previously reported, the U.S. Securities and Exchange Commission (SEC) unanimously voted to approve additional guidance for reporting cybersecurity risks. The release of this guidance underscores the SEC’s...more

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