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SEC Enforcement Actions Reflect Expanding Focus on Advisers’ Policies and Procedures to Prevent Misuse of Material Nonpublic...

The Securities and Exchange Commission (SEC) recently brought settled enforcement actions against two registered investment advisers for failing to establish, maintain, and enforce written policies and procedures reasonably...more

Ongoing SEC Marketing Rule Enforcement Sweep Results in Charges Against Investment Advisers

On September 11, 2023, the Securities and Exchange Commission (SEC) charged and settled proceedings with nine registered investment advisers for misrepresenting hypothetical performance of advisory products in connection with...more

Congress Amends Exchange Act, Expanding SEC Enforcement Power

On January 1, 2021, amendments to Section 21(d) of the Securities Exchange Act of 1934 (Exchange Act) codifying and expanding the power of the Securities and Exchange Commission (SEC or Commission) to obtain disgorgement in...more

Liu v SEC: The US Supreme Court Upholds the SECs Power To Obtain Disgorgement in Civil Actions But With Important Limitations

On June 22, the Supreme Court held in Liu v. SEC that the SEC may obtain disgorgement in federal court cases, as long as the disgorgement does not exceed a wrongdoer’s “net profits and is awarded for victims.” The Court’s...more

United States Court of Appeals for the District of Columbia Denies Petition for Mandamus Seeking to Protect Privilege When Company...

A mandamus petition is an extraordinary remedy that seeks to compel a lower court to take action in extraordinary cases. The U. S. Court of Appeals for the District of Columbia has twice granted mandamus petitions vacating...more

SEC Enforcement Alert: D.C. Circuit Rules Negligent Conduct Is Not “Willful”

On April 30, 2019, the D.C. Circuit issued an important decision in Robare Group, Ltd. v. SEC, Slip Op. No. 16-1453, which rejected the long-standing approach of the Securities and Exchange Commission (Commission or SEC) that...more

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