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New “Shadow Insider Trading” SEC Enforcement Action -- Four Lessons for Private Fund Managers

Last week, the U.S. Securities and Exchange Commission filed a complaint in federal court in California premised on the novel legal theory that the insider trading laws apply where an insider uses confidential information...more

Department of Justice’s 2020 Update Moves the Needle on Guidance for Evaluation of Corporate Compliance Programs

- DOJ’s update offers additional insights into its approach to evaluating corporate compliance programs. - The update places emphasis on compliance programs that are continuously improving, data driven and supported with...more

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