As the SEC closed its fiscal year, it filed three separate enforcement actions against companies for purported violations of Rule 21F-17 under the Securities and Exchange Act of 1934, which prohibits persons from impeding...more
10/10/2023
/ Civil Monetary Penalty ,
Compliance ,
Contract Terms ,
Employment Contract ,
Enforcement Actions ,
Policies and Procedures ,
Remediation ,
Retaliation ,
Rule 21F-17 ,
Securities and Exchange Commission (SEC) ,
Securities Exchange Act ,
Securities Violations ,
Separation Agreement ,
Whistleblower Protection Policies ,
Whistleblowers
Public companies should be mindful not to interfere with or retaliate against whistleblowers, and stretching is best reserved for the yoga mat, not the numbers in a company's public disclosures. So says the U.S. Securities...more
6/12/2023
/ Anti-Retaliation Provisions ,
Dodd-Frank ,
Enforcement Actions ,
Publicly-Traded Companies ,
Retaliation ,
Rule 21F-17 ,
Securities and Exchange Commission (SEC) ,
Securities Exchange Act ,
Securities Violations ,
Severance Agreements ,
Whistleblower Awards ,
Whistleblower Protection Policies ,
Whistleblowers
Ages ago, hieroglyphics were painstakingly etched into stone. They communicated various types of messages, from fables to business transactions, and lasted thousands of years. Today, we still communicate the same type of...more
5/26/2023
/ Broker-Dealer ,
Compliance ,
Data Preservation ,
Department of Justice (DOJ) ,
Discovery ,
Electronic Communications ,
Enforcement Actions ,
Instant Messaging Apps ,
Mobile Devices ,
New Guidance ,
Recordkeeping Requirements ,
Registered Investment Advisors ,
Securities and Exchange Commission (SEC) ,
Securities Exchange Act
Outside of the small circle of federal securities law nerds (we proudly proclaim our membership), the phrase "disclosure controls and procedures" (DCP) rarely garners much attention. However, a recent settled order issued by...more
Section 21F, titled "Whistleblower Incentives and Protection," is a set of provisions within the Securities Exchange Act of 1934 that govern, among other things, the rights and obligations of SEC whistleblowers and the...more
The sun is shining, children are out of school, families are headed off on summer vacations, and the SEC is … bringing enforcement actions against companies for 2020 fraud related to COVID-19 products. One such action was...more
6/8/2022
/ Class Action ,
Coronavirus/COVID-19 ,
Enforcement Actions ,
Fraud ,
Medical Supplies ,
Securities and Exchange Commission (SEC) ,
Securities Exchange Act ,
Securities Violations ,
Settlement Agreements ,
Settlement Negotiations ,
Stock Prices ,
Trading Suspension