On May 12, 2025, Matthew Galeotti, the Head of the Criminal Division of the Department of Justice (“DOJ”), announced changes to DOJ’s white collar enforcement priorities and corporate cooperation policy. During a speech on...more
As President Donald J. Trump wraps up his first two months in office, we review the changes that have taken place at the SEC. Prior to taking office, President Trump announced his intent to appoint Paul Atkins to replace Gary...more
On November 22, 2024, the Securities and Exchange Commission (the “SEC”) published its enforcement results for fiscal year of 2024. The report shows a mixed result. The SEC only brought 583 actions in FY 2024, a 26% decrease...more
On September 9, 2024, the Hon. William Orrick of the District of Northern California imposed the maximum penalty sought by the Securities and Exchange Commission (“SEC”) against Defendant Matthew Panuwat—a civil fine of three...more
On June 18, 2024, the Securities and Exchange Commission (“SEC”) announced a $2.1 million civil penalty settlement of charges against R.R. Donnelley & Sons (“RRD”), a global provider of business communications services and...more
On June 26, 2024, the Supreme Court issued a decision in SEC v. Jarkesy, holding that “[w]hen the SEC seeks civil penalties against a defendant for securities fraud, the Seventh Amendment entitles the defendant to a jury...more
7/12/2024
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Administrative Law Judge (ALJ) ,
Administrative Proceedings ,
Enforcement Actions ,
Enforcement Authority ,
Jury Trial ,
SCOTUS ,
SEC v Jarkesy ,
Securities and Exchange Commission (SEC) ,
Securities Exchange Act of 1934 ,
Securities Fraud ,
Securities Regulation ,
Seventh Amendment
On May 29, 2024, the Securities and Exchange Commission filed a motion for final judgment, seeking to impose civil penalties in its first enforcement action brought on the theory of “shadow trading.”...more
On April 5, 2024, after an eight-day trial, a jury found Matthew Panuwat liable for violating insider trading laws. Commenting on the Securities and Exchange Commission’s victory, Gurbir Grewal, the agency’s Director of the...more
On November 14, 2023, the Securities and Exchange Commission (the “SEC”) published its enforcement results for fiscal year 2023. FY23 was another active year in terms of SEC enforcement, with a 3 percent increase in total...more
12/6/2023
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Cryptocurrency ,
Cybersecurity ,
Enforcement Actions ,
Environmental Social & Governance (ESG) ,
Fraud ,
Recordkeeping Requirements ,
Securities and Exchange Commission (SEC) ,
Securities Violations ,
Unregistered Securities ,
Whistleblowers
Presented below is a highlight of eight noteworthy enforcement actions the Securities and Exchange Commission has taken against investment advisers through the second quarter of 2023. Since the beginning of this year, the...more
Under the leadership of SEC Chairman Gary Gensler and Director of Enforcement Gurbir Grewal, the SEC has consistently prioritized compliance with books and recordkeeping obligations for registered broker-dealers, especially...more
In March 2022, as it does every year, the Securities and Exchange Commission’s Division of Examinations (EXAMS) published its Examination Priorities, designed to highlight areas that the Agency views to be worthy of...more
A California Court recently allowed the Securities and Exchange Commission (the “SEC” or “Commission”) to proceed with its first insider trading prosecution based on a theory of “shadow trading.” On January 14, 2022, Judge...more
2/11/2022
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Due Process ,
Enforcement Actions ,
Insider Trading ,
Material Nonpublic Information ,
Materiality ,
Misappropriation ,
Rule 10b-5 ,
Scienter ,
Securities and Exchange Commission (SEC) ,
Securities Exchange Act ,
Securities Violations
A key question for any company considering the issuance of cryptocurrency is whether that digital asset will be treated by regulators as a security, like BP stock, or a commodity, like Bitcoin. In 2019, the Securities and...more
2/4/2022
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Blockchain ,
Cryptocurrency ,
Digital Assets ,
Enforcement Actions ,
FinTech ,
Howey ,
Investment Contract ,
Popular ,
Securities ,
Securities and Exchange Commission (SEC) ,
Securities Violations ,
Unregistered Securities ,
Virtual Currency
On November 18, 2021, the Securities and Exchange Commission (the “Commission”) released its Enforcement Results for fiscal year (“FY”) 2021, which spans from October 1, 2020 to September 30, 2021. The Commission published...more
When it comes to settlements with the SEC’s Division of Enforcement (“Enforcement Division”), a question respondents often ask is how the SEC arrives at a given penalty amount? This blog post will discuss the SEC’s current...more
The SEC is ramping up its cybersecurity disclosure enforcement. While the agency had made significant efforts relating to cybersecurity disclosure previously, there has been surprisingly little SEC activity in this area...more