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First Circuit Reverses SEC Win in $93 Million Investment Adviser Disclosure Case

The court rejects the SEC's per se materiality argument and requires proof of a causal connection between the defendant's allegedly inadequate disclosures and purported unlawful profits....more

SEC Settles Charges with Keurig Over ESG Disclosures

On September 10, 2024, the SEC settled charges against Keurig for "incomplete and inaccurate" ESG disclosures about the recyclability of Keurig's K-Cup pods, signaling a continued focus on environmental-related disclosures...more

DOJ Prevails in Insider Trading Trial Based Solely on Stock Sales Under 10b5-1 Trading Plans

The U.S. Department of Justice ("DOJ") won at trial in its first insider trading prosecution against an executive based exclusively on his sales of stock under 10b5-1 trading plans....more

Fifth Circuit Vacates SEC Private Fund Adviser Rules

The U.S. Court of Appeals for the Fifth Circuit held that the new SEC regulation of private fund advisers exceeded the agency's statutory authority....more

SEC Prevails in Novel "Shadow Trading" Insider Trading Trial

The Securities and Exchange Commission ("SEC") won at trial in its first "shadow trading" case, holding a corporate official liable for insider trading for using nonpublic information about his company's acquisition to trade...more

SEC Enforcement in Financial Reporting and Disclosure: 2023 Year-End Update

We are pleased to present our latest update on financial reporting and issuer disclosure enforcement activity. This White Paper primarily focuses on the U.S. Securities and Exchange Commission’s (“SEC”) enforcement activity...more

Insider Trading Enforcement in 2022

Each year, the Department of Justice ("DOJ"), the Securities and Exchange Commission ("SEC"), and in recent years, the Commodity Futures Trading Commission ("CFTC") dedicate substantial resources to investigating and...more

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