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2025 Digital Asset Developments - Navigating Change: First 100 Days Under the Trump Administration

We are pleased to share with you our latest publication, “Navigating Change: First 100 Days under the Trump Administration,” authored by our Digital Assets + Blockchain team. This retrospective examines the pivotal...more

SEC Briefs Disgorgement and Investor Harm in Navellier v. SEC

In the recent Supreme Court case, Navellier & Associates, Inc. v. Securities and Exchange Commission (SEC), the petitioners sought a writ of certiorari challenging the decisions of the lower courts regarding the scope of...more

First Circuit Questions Materiality in SEC's Case Against Commonwealth Equity Services

On April 1, the U.S. Court of Appeals for the First Circuit vacated a summary judgment ruling in favor of the Securities and Exchange Commission (SEC) against Commonwealth Equity Services, LLC, also known as Commonwealth...more

SEC Reportedly Announces Major Reorganization of Enforcement and Exams Divisions

The U.S. Securities and Exchange Commission (SEC) has reportedly announced internally a major reorganization of its enforcement and exams divisions. This restructuring, effective April 9, 2025, was detailed in a staff memo...more

District Judge Orders Return of Mootness Fees in Akorn Shareholder Lawsuits and Hints at Further Sanctions

In a decision that resonates with many critics of mootness fees, a U.S. district judge for the Northern District of Illinois ordered counsel for Akorn Inc. shareholders to return $332,500 in attorneys’ fees extracted from a...more

Navigating 2025: The SEC's Evolving Role in Cryptocurrency Enforcement — The Crypto Exchange Podcast [Audio]

In this episode of Crypto Exchange, Ethan Ostroff and Alexandra Barrage are joined by partners Joanna Cline and Jay Dubow to discuss the evolving landscape of the SEC's enforcement actions involving cryptocurrencies. The...more

The SEC Weighs In on Meme Coins

In a stated effort to provide greater clarity on the application of federal securities laws to “crypto assets,” the Securities and Exchange Commission’s (SEC) Division of Corporation Finance has released its views on “meme...more

SEC Reportedly Plans to Cut Regional Directors as Cost-Saving Measure

According to news sources, including Reuters, on Friday, February 21, the U.S. Securities and Exchange Commission (SEC) reportedly informed regional directors at its 10 regional offices that it plans to eliminate their roles...more

The SEC's New Cryptocurrency Task Force: A Step Toward Regulatory Clarity

On Jan. 21, 2025, Mark T. Uyeda, the acting chairman of the U.S. Securities and Exchange Commission (SEC), announced the launch of a cryptocurrency task force. This task force, led by SEC Commissioner Hester Peirce, with...more

US v. Brown: District of Columbia Circuit Rules on Compelled Biometric Unlocking of Cellphones

On January 17, the District of Columbia Circuit issued a pivotal opinion regarding the Fifth Amendment rights of a defendant-appellant compelled by the FBI to unlock his cellphone using his thumbprint. The D.C. Circuit’s...more

SEC 2024 Enforcement Results: A Decline in Total Enforcement, but a Record-Breaking Recovery of Financial Remedies

On November 22, the Securities and Exchange Commission (SEC) announced its enforcement results for fiscal year (FY) 2024. As compared to FY 2023, the Division of Enforcement (the division) reported a 26% decline in the total...more

6 Considerations to Determine if a Cyber Incident Is Material

In late June, the staff of the U.S. Securities and Exchange Commission’s Division of Corporation Finance released five new compliance and disclosure interpretations regarding the disclosure of material cybersecurity incidents...more

The SEC’s Division of Examinations Announces 2025 Priorities

On October 21, the Securities and Exchange Commission’s (SEC) Division of Examinations announced its 2025 examination priorities (2025 guidance) for registered investment advisers and investment companies, broker-dealers,...more

Prioritize Document Review for SEC Whistleblower Rule Compliance

If you have not recently reviewed your company’s documents to ensure they comply with Securities and Exchange Commission (SEC) whistleblower protection rules, you should put it at the top of your to-do list. On September 9,...more

SEC Charges Broker-Dealer and Two Affiliated Investment Advisers With Violating Whistleblower Protection Rule

On September 4, the Securities and Exchange Commission (SEC) issued an order against three investment adviser firms for violating the whistleblower protections of Rule 21F-17(a) under the Securities Exchange Act of 1934. This...more

Supreme Court Limits SEC’s In-House Adjudication

On June 27, the U.S. Supreme Court released a 6-3 decision in SEC v. Jarkesy, et al., ending the Securities and Exchange Commission’s (SEC) long-standing use of in-house administrative law judge (ALJ) tribunals in cases where...more

FINRA’s Crackdown on Firms’ Use of Social Media Influencers Continues

The Financial Industry Regulation Authority’s (FINRA) Enforcement Division recently announced a resolution to a nearly two-and-a-half-year investigation in which TradeZero America, Inc. (TradeZero) agreed to pay a fine of...more

SEC Charges Investment Advisor for Misleading Disclosures About Its Work With Short Publishers

On June 11, the Securities and Exchange Commission (SEC) announced the first settled case in its ongoing review of collaborations between investment advisors and short publishers. The SEC fined affiliated investment advisors...more

US Supreme Court to Hear Nvidia Crypto Mining Case on Securities Pleading Standard

On June 17, the U.S. Supreme Court granted certiorari in Nvidia Corp. v. E. Ohman J:or Fonder AB, agreeing to hear Nvidia’s appeal of a Ninth Circuit ruling that revived shareholders’ fraud claims regarding Nvidia’s...more

US Supreme Court Limits Scope of Omission Liability for Section 10(b) Securities Fraud Claims

On April 12, in a long-awaited and pivotal decision, the U.S. Supreme Court unanimously ruled that private plaintiffs may not plead a federal securities fraud claim under Section 10(b) of the Securities Exchange Act of 1934...more

FINRA’s First Disciplinary Action Targeting Firm’s Use of Social Media Influencers

The Financial Industry Regulatory Authority’s (FINRA) Enforcement Division recently announced its first settlement involving a firm’s supervision of social media influencers. The respondent, M1 Finance LLC (M1), is a...more

The SEC Voluntarily Stays Climate-Related Disclosure Rules Pending Eighth Circuit Judicial Review

On April 4, the Securities and Exchange Commission (SEC) issued a stay on the implementation of its newly enacted climate impact disclosure rules. This decision is connected to a challenge to the rules currently pending in...more

2023 Year-In-Review: Key Enforcement Initiatives and Cases in Crypto, Cyber, SPACs, Whistleblowers, and the Future of...

It was a busy year for enforcement activity in the cyber, crypto, SPAC, and whistleblower spaces, with several pending actions that will likely have wide-ranging implications in 2024. We are also awaiting a ruling from the...more

11th Circuit Rules Against SEC Penny-Stock Ban

In a 2-1 opinion issued on February 14, 2024, an Eleventh Circuit panel partially reversed a lower court ruling that would have barred a defendant from participating in future penny-stock offerings. The majority found it was...more

How to Avoid a Similar Fate? SEC Charges Firms With Record-Keeping Violations for Off-Channel Communications

On February 9, the Securities and Exchange Commission (SEC) announced settlements with 16 firms relating to record-keeping violations stemming from off-channel communications totaling $81 million. The 16 firms were five...more

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