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Sanctions Disclosure Requirements Securities and Exchange Commission (SEC)

Guidepost Solutions LLC

Investment Advisers and Generative AI

Start Planning Now to Reduce Your Increased Money Laundering, Sanctions, and Conflicts of Interest Risks The introduction and use of generative artificial intelligence (GenAI) and predictive data analytics (PDAs) by...more

A&O Shearman

It is Annual Report Time—Recent Developments and Trends for the Preparation of the 2023 Form 20-F

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Foreign private issuers (FPIs) with a calendar year end must file their annual report on Form 20-F with the U.S. Securities and Exchange Commission (the SEC) no later than April 30, 2024, and this memorandum provides an...more

Kohn, Kohn & Colapinto LLP

Using Whistleblower Laws to Hold Polluters Accountable

Global political and business leaders have purported ambitious climate-focused goals for the decades ahead, such as eliminating landfill waste by 2030, transitioning to 100% renewable energy use by 2035, and achieving...more

Allen Matkins

If The SEC Favors Full Disclosure, Why Does It Have A "Gag Rule"?

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In 1972, the Securities and Exchange Commission announced its "policy not to permit a defendant or respondent to consent to a judgment or order that imposes a sanction while denying the allegations in the complaint or order...more

Goodwin

SEC Publishes Sample Climate Change Comment Letter

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In This Issue. The U.S. Securities and Exchange Commission (SEC) published a sample comment letter on climate change disclosures; the Financial Industry Regulatory Authority (FINRA) is conducting a review of brokerage firm...more

Akin Gump Strauss Hauer & Feld LLP

Top 10 Topics for Directors in 2019

1. Corporate Culture - The corporate culture of a company starts at the top, with the board of directors, and directors should be attuned not only to the company’s business, but also to its people and values across the...more

Carlton Fields

Recalls of Loaned Securities by Insurance Dedicated Funds

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In March, the SEC sanctioned the investment advisers of two funds supporting variable insurance contracts for inadequate disclosure about the funds’ recalls of loaned portfolio securities in advance of the securities’...more

Jones Day

SEC Enforcement in Financial Reporting and Disclosure—2017 Year-End Update

Jones Day on

2017 will most likely be remembered as a year of transition, as the Securities and Exchange Commission’s enforcement actions indicate, at least in the near term, an emphasis on specific initiatives and retail investor...more

Orrick, Herrington & Sutcliffe LLP

SEC Brings Post-MCDC Enforcement Actions Against Underwriter and Officials

On April 5, 2017 the SEC released two orders instituting cease-and-desist proceedings (consent decrees) which are the first post-MCDC cases finding securities law violations based on misstatements in official statements...more

Ballard Spahr LLP

Investment Management Update

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Investment Adviser AXA Wins Excessive Fee Trial - A federal judge in New Jersey has ruled in favor of AXA Equitable Life Insurance Company (AXA Equitable) and its wholly owned subsidiary, AXA Equitable Funds Management...more

Burr & Forman

SEC Sanctions 71 Municipal Issuers for Misstatements

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On August 24, the SEC announced settled administrative actions against 71 state and local issuers arising from $3.7 trillion in municipal securities offerings.  The Commission alleged the issuers made false statements...more

Morrison & Foerster LLP - Structured Products

Structured Thoughts: News for the financial services community, Volume 6, Issue 7

Structured Products Offerings and Research Reports: Introduction - Structured products are sold by broker-dealers, many of which are affiliates of large investment banks. The equity research group of the same...more

Foley & Lardner LLP

A Compilation of Enforcement and Non-Enforcement Actions

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Non-Enforcement - SEC Decides Against Mounting an Appeal in Koch Ruling - The July 2015 ruling by the D.C. Circuit Court in Koch v. SEC will apparently not be challenged by the SEC. The Court ruled in that...more

Goodwin

Financial Services Weekly News - October 2015 #3

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Regulatory Developments: FINRA Requests Comment on Rules Relating to Financial Exploitation of Vulnerable Adults - On Oct. 15 FINRA published Regulatory Notice 15-37, requesting comment on proposed amendments to...more

Foley & Lardner LLP

A Compilation of Enforcement and Non-Enforcement Actions

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Non-Enforcement Cybersecurity Is At the Top of SEC Examination Concerns In a recent SEC “risk alert” for registered broker-dealers and investment advisers, the SEC’s Office of Compliance Inspections and Examinations (OCIE)...more

Dorsey & Whitney LLP

SEC Sanctions KKR Over Fee Allocations

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The SEC filed its first action involving a private equity fund and broken deal expenses. By the time the Commission discovered the question the firm realized it did not have a disclosure policy, retained a consultant to study...more

Burr & Forman

SEC Announces First Wave of MCDC Underwriter Sanctions

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The Securities Exchange Commission announced June 18 the first major wave of underwriter sanctions under its Municipalities Continuing Disclosure Cooperation (“MCDC”) Initiative. The SEC sanctioned 36 municipal underwriting...more

Locke Lord LLP

The Foreign Corrupt Practices Act: At a Glance

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In this issue: - FCPA AT A GLANCE - THE ANTI-BRIBERY PROVISIONS OF THE FCPA - TO WHOM THE ANTI-BRIBERY PROVISIONS APPLY - THE PAYMENT ELEMENT - THE CORRUPT INTENT ELEMENT - WHO IS A...more

Cooley LLP

Blog: More “Broken Windows” Enforcement From The SEC?

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Yesterday, the SEC announced that it had sanctioned ten companies (generally, smaller reporting companies traded on OTC Link) for failing to make required Form 8-K disclosures related to financings and unregistered stock...more

Skadden, Arps, Slate, Meagher & Flom LLP

"Disclosure and Collateral Consequences of Enforcement Actions for Regulated Financial Services Firms"

Financial services firms facing enforcement proceedings at the hands of the U.S. Securities and Exchange Commission (SEC) or any other financial industry regulator must consider disclosure obligations in the context of the...more

Dorsey & Whitney LLP

Barclays Is Sanctioned By The FCA and The SEC

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Barclays took a double hit from regulators yesterday. First the Financial Conduct Authority in the UK fined Barclays Bank Plc, about £38 million for putting £16.5 billion of client assets at risk. Then the SEC imposed a $15...more

Holland & Knight LLP

Iran Sanctions Update

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The United States continues to impose additional layers of sanctions on Iran. The rate of change and complexity of U.S. sanctions laws present challenges, particularly where these sanctions have extraterritorial effect on the...more

Snell & Wilmer

Disclosures Under the Iran Threat Reduction and Syria Human Rights Act of 2012

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In August 2012, the Iran Threat Reduction and Syria Human Rights Act of 2012 (ITR) was signed into law. ITR is part of a broad sanctions strategy designed to deter the pursuit of nuclear weapons and support for terrorism and...more

Stinson - Corporate & Securities Law Blog

SEC Releases New CD&Is on Iran Disclosures

The Iran Threat Reduction and Syria Human Rights Act (ITRA), signed into law on August 10, 2012, added new Section 13(r) to the Exchange Act, requiring issuers that file reports under Section 13(a) of the Exchange Act to...more

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