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Supreme Court Limits the Ability of Plaintiffs to Pursue Claims Against Issuers in Direct Listings

On June 1, 2023, in Slack Technologies, LLC, et al., v. Pirani, the Supreme Court unanimously held that plaintiffs alleging a violation of Section 11 of the Securities Act of 1933 (“Securities Act”) must plead and prove that...more

Supreme Court Rejects Objective Standard for Scienter for False Claims Act

On June 1, 2023, the United States Supreme Court decided two consolidated cases, United States ex rel. Schutte v. SuperValu Inc. and United States ex rel. Proctor v. Safeway, 589 U.S. ___ (2023), holding that a defendant’s...more

New York Looks to Bolster Its Lead as Digital Regulator with CRPTO Act

New York State Attorney General Letitia James has announced new proposed amendments to the state’s General Business Law that would roll out a number of protections to cryptocurrency investors that are currently enjoyed by...more

Supreme Court Decision in Axon Enterprise, Inc. v. FTC Has Wide Reaching Implications for Administrative Enforcement Proceedings

On April 14, 2023, the Supreme Court issued a consolidated opinion in Axon Enterprise, Inc. v. FTC and SEC v. Cochran.[1] We previously covered the oral argument in these cases here. These cases address whether respondents...more

SEC Proposed New Rule and Extensive Updates to Existing Rules on Cybersecurity

On March 15, 2023, the Securities and Exchange Commission (“SEC”) proposed a new rule concerning cybersecurity risk management as well as updates to Regulations S-P and SCI (Systems Compliance Integrity).[1] With these...more

SEC Warns Newly-Registered Advisers to Avoid Three Common Missteps

The U.S. Securities and Exchange Commission’s Division of Examinations (“the Division”) issued a new Risk Alert on March 27, 2023 that takes newly-registered investment advisers to task for three recurring issues its staff...more

NBA-Branded NFTs May Be Securities S.D.N.Y. Finds

On February 22, 2023, a judge in the Southern District of New York ruled that a class action lawsuit may proceed alleging that Dapper Labs, Inc. violated federal securities laws when it issued of a series of non-fungible...more

SEC Division of Examination Announces 2023 Priorities

On Tuesday, February 7, 2023, the Securities and Exchange Commission’s (“SEC”) Division of Examinations announced its 2023 examination priorities, which provide insights into the areas the Division believes present potential...more

Securities Class Action Filings – Cornerstone Research 2022 Year in Review

Earlier this month, Cornerstone Research and the Stanford Law School Securities Class Action Clearinghouse released a report analyzing 2022 securities class action filings. The report indicates that overall securities class...more

Managed Funds Association and Others Urge Narrower Enforcement of Advisers Act’s Recordkeeping Requirements

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

Second Circuit Opines on Scope of Supreme Court’s Kelly Precedent for Misappropriation of Confidential Government Information

In United States v. Blaszczak, the Second Circuit recently remanded a criminal conviction concerning the misappropriation of confidential information to the District Court in light of the Supreme Court’s decision in Kelly v....more

SEC v. LBRY, Inc.: Federal Court Finds LBRY’s Crypto Token as a Security

It is no secret that over the last several years, there has been an exponential increase in the utilization of blockchain and digital assets. Crypto trading and lending platforms have grown rapidly and the total crypto market...more

An Overview of the SEC, SDNY and CFTC Cases Against Sam Bankman-Fried

As has been widely reported, last week, the SEC, CFTC, and U.S. Attorney’s Office (“USAO”) for the Southern District of New York (“SDNY”) announced charges against Samuel Bankman-Fried (“SBF”), the co-founder and majority...more

SEC Asks Companies to Disclose Information on Crypto Exposure

On Thursday, December 8, 2022, the Securities and Exchange Commission (“SEC”) published a notice to its website informing companies of their potential disclosure obligations regarding their crypto assets....more

Supreme Court Hears Oral Arguments in SEC v. Cochran, a Case Concerning Challenges to Federal Administrative Proceedings

On November 7, 2022, the U.S. Supreme Court heard oral arguments in the cases of SEC v. Cochran and Axon Enterprise, Inc. v. FTC, which address whether respondents in federal administrative proceedings have the ability to...more

SEC Moves Against $300 Million Crypto Ponzi Scheme

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

Deputy Attorney General Announces Further Revisions to Corporate Criminal Enforcement Policies

On September 15, 2022, Deputy Attorney General (“DAG”) Lisa Monaco announced a series of changes to the United States Department of Justice’s (the “Department” or “DOJ”) corporate enforcement policies. This follows a prior...more

First NFT-based Insider Trading Case Tees Up Important Questions for Digital Asset Fraud Prosecutions

This summer, the U.S. Attorney’s Office for the Southern District of New York broke new ground in its oversight of fraud involving digital assets when it brought charges against Nathaniel Chastain related to an insider...more

A Brief Overview of the Proposed Responsible Financial Innovation Act by U.S. Senators Kirsten Gillibrand and Cynthia Lummis

On June 6, 2022, U.S. Senator Kirsten Gillibrand of New York and U.S. Senator Cynthia Lummis of Wyoming proposed federal regulation of digital assets in the Responsible Financial Innovation Act (“RFIA”)....more

SEC, CFTC, and SDNY Charge Archegos Capital Management and Its Owner and Executives with Fraud: Implications for Family Offices

On April 27, 2022, the SEC filed suit against family office Archegos Capital Management, LP, as well as its Founder/Owner Sung Kook (Bill) Hwang, CFO Patrick Halligan, Head Trader William Tomita, and Chief Risk Officer Scott...more

Pair of Legal Developments leave SEC In-House Legal Courts in Crosshairs

A pair of recent legal developments cast doubt on the long term ability of the Securities and Exchange Commission (“SEC”) to try contested actions before the agency’s in-house administrative law judges (“ALJ”).  First, the...more

SEC Proposes New Rule on Climate Related Disclosures

Recently, the Securities and Exchange Commission (“SEC”) proposed a new rule concerning the disclosure of “certain climate-related information in their registration statements and annual reports” as well as “certain...more

ESG Funds Must Tread Carefully as Russia Sanctions Bite

The full-scale invasion of Ukraine by a revanchist Russia continues to dominate headlines as the war enters its second month. While the sometimes-terrible choices facing those living in the conflict zone are unparalleled,...more

The SEC Begins Regulation of Cryptocurrency Interest Account Offerings

On June 29, 2021, a major cryptocurrency exchange (the “Crypto Exchange”) announced a new program called “Lend” in which it proposed offering customers a 4% interest rate on cryptocurrency tied to USD....more

Securities Class Action Filings – Cornerstone Research 2021 Year in Review

Securities class action case filings plunged in 2021 compared to the number of similar cases filed in 2020.  According to Cornerstone Research’s 2021 Year in Review report, there were 218 securities class action cases filed...more

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