On May 12, 2025, Matthew Galeotti, Head of the Criminal Division of the Department of Justice (“DOJ”), published a memorandum outlining the DOJ’s current investigation and enforcement priorities for prosecuting corporate and...more
The American Bar Association held its 40th Annual National Institute on White Collar Crime conference on March 5, 6, and 7, 2025, in Miami, Florida. The conference featured robust panel discussions with the federal and state...more
On February 5, 2025, newly appointed U.S. Attorney General Pam Bondi issued a memorandum titled “Total Elimination of Cartels and Transnational Criminal Organizations” (the February 5 Memorandum), which outlined a broad...more
On November 22, 2024, the Securities and Exchange Commission (the “SEC” or “Commission”) announced its enforcement results for the fiscal year (“FY”) 2024. Though the SEC filed only 583 total enforcement actions in FY 2024—a...more
The annual ALI-CLE Accountants’ Liability Conference occurred in Washington, D.C. on May 16 and 17, 2024 and was co-hosted by Junaid A. Zubairi, Chair of Vedder Price’s Government Investigations and White Collar Defense...more
The U.S. Securities and Exchange Commission (the “SEC”) held its annual SEC Speaks conference—after a hiatus in 2023—on April 3 and 4, 2024 in Washington, D.C. The conference featured remarks from Chair Gary Gensler,...more
Fireside Chat with Attorney General Merrick Garland -
A highlight of the conference was a fireside chat with Attorney General Merrick Garland.
AG Garland first discussed the important lead the United States has with...more
On November 14, 2023, the Securities and Exchange Commission (the “SEC” or the “Commission”) announced its enforcement results for fiscal year (“FY”) 2023, which ended on September 30, 2023. The SEC’s FY 2023 results...more
On Thursday, June 29, 2023, the Securities and Exchange Commission (SEC) announced the filing of four civil insider trading cases involving a variety of alleged insider trading violations. These cases were brought against a...more
On June 22, 2020, the U.S. Supreme Court (the “Court”) ruled 8–1 in favor of the Securities and Exchange Commission’s (“SEC”) right to seek disgorgement of ill-gotten gains in the landmark case of Liu v. SEC, 591 U.S. __...more
6/26/2020
/ 15 U.S.C. § 78u(d)(5) ,
Administrative Authority ,
Business Expenses ,
Calculation of Damages ,
Corporate Misconduct ,
Disgorgement ,
Enforcement Actions ,
Equitable Relief ,
Kokesh v SEC ,
Lack of Authority ,
Liu v Securities and Exchange Commission ,
Net Profits ,
Remedies ,
SCOTUS ,
Securities and Exchange Commission (SEC)
In an address delivered on May 12, 2020, Steven Peikin, Co-Director of the SEC’s Division of Enforcement, discussed the Staff’s response and adjustment to the COVID-19 pandemic. During his remarks, Mr. Peikin discussed the...more
As we continue to monitor the SEC’s enforcement activity during this pandemic, it is also important to look ahead to potential future enforcement trends and priorities once a sense of normalcy returns. One initial thing that...more
One of the trends emerging from the criminal and civil enforcement landscape over the last few weeks appears to be an enhanced regulatory focus on insider trading. Given the market turmoil and ongoing disruption to routine...more
Junaid A. Zubairi, Chair of Vedder Price’s Government Enforcement and Special Investigations group, served as co-chair of the 2019 ALI-CLE Accountants’ Liability program on October 17 and 18, 2019 in Washington, DC. The...more
11/7/2019
/ Audits ,
Chief Compliance Officers ,
Enforcement Actions ,
Enforcement Statistics ,
FASB ,
Financial Statements ,
GAAP ,
GAAS ,
Internal Controls ,
Lucia v SEC ,
Non-GAAP Financial Measures ,
PCAOB ,
Rule 10b-5 ,
Securities and Exchange Commission (SEC)
The U.S. Securities and Exchange Commission (the “SEC” or the “Commission”) held its annual SEC Speaks conference in Washington, DC on April 8 and 9, 2019. The conference featured remarks from the Chairman and commissioners,...more
4/12/2019
/ Administrative Law Judge (ALJ) ,
Enforcement Actions ,
Foreign Corrupt Practices Act (FCPA) ,
Investigations ,
Investment Banks ,
Investors ,
Kokesh v SEC ,
Lorenzo v SEC ,
SCOTUS ,
Securities and Exchange Commission (SEC) ,
Securities Exchange Act ,
Securities Violations
On June 21, 2018, the United States Supreme Court resolved a circuit split on the question of whether administrative law judges (“ALJs”) of the Securities and Exchange Commission (the “SEC” or the “Commission”) qualify as...more
7/3/2018
/ Administrative Agencies ,
Administrative Law Judge (ALJ) ,
Administrative Proceedings ,
Appeals ,
Appointments Clause ,
Constitutional Challenges ,
Enforcement Actions ,
Final Written Decisions ,
Lucia v SEC ,
Officers of the United States ,
Remand ,
Reversal ,
SCOTUS ,
Securities and Exchange Commission (SEC) ,
Securities Violations ,
Special Trial Judges (STJs)
On February 21, 2018, the United States Supreme Court (the “Supreme Court”) resolved a circuit split on the question of whether the whistleblower anti-retaliation provision in Section 922 of the Dodd-Frank Wall Street Reform...more
3/6/2018
/ Anti-Retaliation Provisions ,
Digital Realty Trust Inc v Somers ,
Dodd-Frank ,
Internal Reporting ,
Reporting Requirements ,
Retaliation ,
Sarbanes-Oxley ,
SCOTUS ,
Securities and Exchange Commission (SEC) ,
Securities Violations ,
Whistleblower Protection Policies ,
Whistleblowers
The U.S. Securities and Exchange Commission (“SEC” or the “Commission”) held its annual SEC Speaks conference in Washington, DC on February 23 and 24, 2018 and provided remarks from the Chairman and commissioners, discussions...more
3/1/2018
/ Absolute Immunity ,
Administrative Law Judge (ALJ) ,
Asset Management ,
Asset Recovery ,
Broker-Dealer ,
Complex Financial Products ,
Cybersecurity ,
Enforcement Actions ,
Insider Trading ,
Investment Adviser ,
Market Abuse ,
OCIE ,
Policies and Procedures ,
Retail Investors ,
Securities and Exchange Commission (SEC) ,
Whistleblower Protection Policies
Earlier this week, the U.S. Supreme Court (“Supreme Court”) issued its decision in Kokesh v. SEC, No. 16-529, unanimously holding that disgorgement claims brought as part of enforcement actions by the U.S. Securities and...more
6/8/2017
/ Disgorgement ,
Enforcement Actions ,
Investment Adviser ,
Kokesh v SEC ,
Misappropriation ,
Penalties ,
SCOTUS ,
Securities and Exchange Commission (SEC) ,
Securities Violations ,
Split of Authority ,
Statute of Limitations