In Hollywood, the sequel (or, even more so, the third installment) is rarely as good as the original movie. In the world of enforcement, the same rings true....more
3/6/2025
/ Artificial Intelligence ,
Consent Order ,
Corporate Governance ,
Corporate Misconduct ,
Criminal Conspiracy ,
Criminal Convictions ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Enforcement Actions ,
False Statements ,
Financial Crimes ,
Regulatory Requirements ,
Securities and Exchange Commission (SEC) ,
Securities Fraud ,
Securities Violations ,
Subsidiaries ,
White Collar Crimes
The dog days of late summer are a frenzied time within the SEC's Division of Enforcement as staff work feverishly to complete their investigations and secure the requisite yes vote from a majority of commissioners to...more
12/9/2024
/ Artificial Intelligence ,
Cyber Incident Reporting ,
Enforcement Actions ,
Enforcement Priorities ,
Enforcement Statistics ,
Failure To Disclose ,
Fraud ,
Insider Trading ,
Market Manipulation ,
Private Funds ,
Securities and Exchange Commission (SEC) ,
Securities Regulation ,
Securities Violations
The SEC on Oct. 30, 2023, filed a landmark cybersecurity enforcement action against SolarWinds Corp. (SolarWinds) and the company's current Chief Information Security Officer (CISO) Timothy Brown. The SEC's complaint alleges...more
11/7/2023
/ Cyber Attacks ,
Cybersecurity ,
Data Breach ,
Enforcement Actions ,
Failure To Disclose ,
Information Technology ,
NIST ,
Popular ,
Securities and Exchange Commission (SEC) ,
Securities Regulation ,
Securities Violations ,
SolarWinds
Digital assets are not the only coins drawing regulatory scrutiny these days. Earlier this year, the U.S. Securities and Exchange Commission (SEC) announced that it filed a complaint against California-based Red Rock Secured...more
10/27/2023
/ 401k ,
CFTC ,
Digital Assets ,
Enforcement Actions ,
Fraud ,
Individual Retirement Account (IRA) ,
Investment Advisers Act of 1940 ,
Parallel Proceedings ,
Rare Earth Metals ,
Retirement Plan ,
Securities and Exchange Commission (SEC) ,
Securities Exchange Act ,
Securities Violations
As the SEC closed its fiscal year, it filed three separate enforcement actions against companies for purported violations of Rule 21F-17 under the Securities and Exchange Act of 1934, which prohibits persons from impeding...more
10/10/2023
/ Civil Monetary Penalty ,
Compliance ,
Contract Terms ,
Employment Contract ,
Enforcement Actions ,
Policies and Procedures ,
Remediation ,
Retaliation ,
Rule 21F-17 ,
Securities and Exchange Commission (SEC) ,
Securities Exchange Act ,
Securities Violations ,
Separation Agreement ,
Whistleblower Protection Policies ,
Whistleblowers
We return once more to the issue of public company executive perquisites or "perks" – a topic we anticipated last year would "be a hot-button enforcement issue for the foreseeable future." We were not wrong. In light of the...more
7/11/2023
/ Compensation & Benefits ,
Cooperation ,
Corporate Governance ,
Enforcement Actions ,
Executive Compensation ,
Failure To Disclose ,
Perks ,
Publicly-Traded Companies ,
Regulatory Violations ,
Securities and Exchange Commission (SEC) ,
Securities Violations ,
Self-Reporting
Public companies should be mindful not to interfere with or retaliate against whistleblowers, and stretching is best reserved for the yoga mat, not the numbers in a company's public disclosures. So says the U.S. Securities...more
6/12/2023
/ Anti-Retaliation Provisions ,
Dodd-Frank ,
Enforcement Actions ,
Publicly-Traded Companies ,
Retaliation ,
Rule 21F-17 ,
Securities and Exchange Commission (SEC) ,
Securities Exchange Act ,
Securities Violations ,
Severance Agreements ,
Whistleblower Awards ,
Whistleblower Protection Policies ,
Whistleblowers