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Gurbir Grewal Named as New Director of SEC Enforcement Division

The Securities and Exchange Commission (SEC or Commission) announced that New Jersey Attorney General Gurbir Grewal will become the next director of its Enforcement Division (Division), after resigning his New Jersey's...more

Companies Should Exercise Caution When Addressing Anonymous Whistleblower Complaints

Public companies should proceed with caution when receiving and investigating anonymous whistleblower complaints. Several public companies recently received whistleblower complaints from an anonymous source – each with...more

Recent Developments in Auditing Could Create Tensions, Leading to More Regulatory Actions

Public companies should prepare for a more strenuous auditing process, and the increased likelihood that the information that they share with their auditors could be compelled by the Securities and Exchange Commission (SEC)...more

SEC Cases Offer Insight into Its Approach to Alleged COVID-19 Securities Fraud

A remote status conference was held June 28 for United States v. Mark Schena, currently pending in the U.S. District Court for the Northern District of California. In the recently unsealed superseding indictment, the SEC...more

Gensler's SEC Agenda: Commitment to ESG and Increased Disclosures

On June 11, the Biden administration’s Office of Information and Regulatory Affairs (OIRA) released the Securities and Exchange Commission’s (SEC or Commission) rulemaking agenda (Rulemaking Agenda) as part of the Spring 2021...more

SolarWinds Cyberattack Generates Recent Widespread SEC Enforcement Requests

The SEC’s Division of Enforcement recently issued voluntary information requests to several public companies, inquiring about the details of any impact arising from the widely publicized December 2020 SolarWinds cyberattack....more

SEC Commentary Highlights Increased Focus on Data Analytics in Identifying Potential Securities Law Violations (UPDATED)

Recent commentary by Diana Tani, an assistant regional director with the SEC, at the Securities Enforcement West web conference emphasized the agency's focus on data-driven investigations. Two areas targeted for recent...more

It's Official: Circuits are Split on Domestic Transaction Test

Summary - The U.S. Courts of Appeal for the First and Second Circuits have split on the issue of whether a plaintiff must satisfy the Second Circuit’s “predominantly foreign” test (set forth in Parkcentral Global Hub Ltd....more

SEC Has Its Eye on SPACs

SPACs — short for “special purpose acquisition companies” — recently have drawn significant interest by companies and executives as a more seamless method to conduct an initial public offering. Often referred to as “blank...more

Record-Breaking Year for CFTC Enforcement Division Shows Continued Growth of Enforcement Program and No Slowing Down in FY 2021

Who Needs to Know - Financial Advisors and Institutions, Traders, Investors, Corporations. Why It Matters - As evidenced in the FY 2020 Division of Enforcement Annual Report (Report), the COVID-19 pandemic did not...more

DOJ’s Robust 2020 Pandemic Response Signals Increasing Focus on COVID-19-Related Fraud in 2021

Why It Matters - As evidenced in the recently published 2020 Year in Review Report (Report), the Department of Justice’s Fraud Section (Fraud Section) demonstrated its resilience despite the COVID-19 pandemic, as well as its...more

SEC Creates Climate and ESG Enforcement Task Force

Background - This year, the SEC has established its focus on disclosure and compliance issues related to environmental, social, and governance (ESG) matters. Recent developments by the SEC concerning ESG issues signal that...more

Division of Examinations Issues Risk Alert on Digital Asset Securities

On February 26, the SEC Division of Examinations (Division) (formerly the Office of Compliance Inspections and Examinations) issued a Risk Alert (Alert) relating to the offer, sale, and trading of digital assets that are...more

FINRA Publishes New Annual Report on FINRA’s Examination and Risk Monitoring Program

Why It Matters - The 2021 Report on FINRA’s Examination and Risk Monitoring Program serves as an authoritative resource for member firms to evaluate and, where necessary, enhance their compliance programs and operations...more

Return of More Subpoena Power to SEC’s Division of Enforcement

On February 9, Acting Securities and Exchange Commission (SEC or Commission) Chair Allison Herren Lee announced that senior officers in the SEC’s Division of Enforcement (Division) will once again be authorized to approve the...more

Congress Passes Law Expanding the SEC's Ability to Seek Disgorgement

On Friday January 1, with the Senate’s floor vote to override the president’s veto, Congress passed the 60th annual National Defense Authorization Act (NDAA). Encompassed within the $740.5 billion military spending bill is an...more

Highlights: SEC Division of Enforcement 2020 Annual Report

Who Needs to Know - Public companies and their directors and officers as well as brokers, dealers, investment advisors, investment companies and their associated persons....more

SEC Enforcement Case Offers Important Lessons about Internal Controls and Stock Buybacks

The U.S. Securities and Exchange Commission (SEC) recently settled an enforcement action in which it found that a public company failed to develop and implement adequate controls around a stock buyback program. The action...more

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