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The CFTC is Watching: Enforcement Director Outlines New Priorities

Speaking recently at NYU Law School, David Miller outlined his enforcement philosophy and priorities as the new head of the Commodity Futures Trading Commission’s (CFTC) Division of Enforcement (Division). While emphasizing...more

SEC and CFTC Issue Guidance on the Applicability of Federal Securities Laws to Crypto Assets and Blockchain Activities

On March 17, 2026, the U.S. Securities and Exchange Commission (SEC) issued an Interpretation (the Interpretation) to clarify the application of the federal securities laws to crypto assets. At the same time, the Commodity...more

CFTC Issues Guidance and Advanced Notice of Proposed Rulemaking Relating to Prediction Markets

Prediction markets are online platforms where people can trade “event contacts” that settle based on the outcome of future events with a “yes” or “no” answer, including contracts based on economic indicators, financial...more

DOJ Speaks with One Voice: What the New Department-Wide CEP Means for Corporate Self-Disclosure

On March 10, 2026, the U.S. Department of Justice (DOJ) published its “first-ever” Department-wide Corporate Enforcement and Voluntary Self-Disclosure Policy (the “Department-wide CEP”), which will apply to all corporate...more

SEC Charges Credit Fund Adviser Over Principal Transaction Pricing Practices

On February 25, 2026, the U.S. Securities and Exchange Commission (SEC) charged a credit fund adviser with negligence-based anti-fraud violations and breaches of fiduciary duty in connection with the sale of originated loans...more

SEC Division of Enforcement Publishes Revised Enforcement Manual

On February 24, 2026, the U.S. Securities and Exchange Commission’s (SEC) Division of Enforcement published the first update to its Enforcement Manual in over eight years. The revised manual introduces notable changes to the...more

SDNY Rules Communications With a Public Generative AI Platform Are Not Protected by Attorney-Client Privilege or Work Product...

On October 28, 2025, a grand jury indicted Bradley Heppner on multiple charges, including securities fraud and wire fraud, stemming from his time as an executive of several corporate entities. During a search of Heppner’s...more

The Supreme Court (Again) Takes Up SEC Disgorgement Powers

Disgorgement is a key tool in the enforcement arsenal of the U.S. Securities and Exchange Commission (SEC). It is an equitable remedy that provides the agency with the means to recover ill-gotten gains or, in some cases,...more

Federal Agencies Signal Renewed Focus on Prediction Markets

Prediction markets are online platforms where people can bet on the outcome of future events with a “yes” or “no” answer, including contracts based on sports, popular culture and politics. These markets have exploded in...more

NYAG Suit Against Former CEO for Insider Trading Under Martin Act Signals Greater State Securities Enforcement Ahead

On January 15, 2026, the New York State Attorney General (NYAG) filed a civil suit against the former CEO of Emergent BioSolutions Inc. (Emergent), Robert G. Kramer, alleging that his sales of company shares pursuant to a...more

SEC Investment Management Director Questions ‘Vote-All’ Proxy Practices and Adviser Reliance on Proxy Advisors

Rule 206(4)-6 under the Investment Advisers Act requires a registered investment adviser with proxy voting authority to adopt policies and procedures reasonably designed to ensure that proxies are voted in clients’ best...more

Hedge Clauses in Focus: The SEC Charges an Investment Adviser with Four Advisers Act Violations

The SEC charged the Advisers with four separate violations of the Investment Advisers Act of 1940 (the Advisers Act). Combined, the Advisers were described as having approximately $500 million in regulatory assets under...more

SEC Enforcement Action Targets Insider Trading in the Pharmaceutical Industry

On December 22, 2025, the U.S. Securities and Exchange Commission (SEC) filed a complaint against several defendants for their roles in market manipulation schemes involving two pharmaceutical companies, Olema...more

OFAC Settlement with Blockchain Wallet Provider Spotlights Sanctions Risks for Digital Assets Intermediaries

On December 16, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced an agreement with Exodus Movement, Inc. (Exodus), a provider of digital asset wallets headquartered in Omaha,...more

UK Financial Conduct Authority Permitted to Name a Claims Management Company under Investigation

In early 2024, the UK Financial Conduct Authority (FCA) announced that it intended to make it easier for itself to publish the names of firms under investigation. This led to market-wide uproar as well as criticism in...more

CFTC Announces Changes to Rules Governing Enforcement Investigations and Settlement Recommendations

On December 1, 2025, the Commodity Futures Trading Commission (CFTC) announced amendments to its rules of practice and rules governing investigations, with the stated goal of enhancing transparency, fairness and due process....more

SEC Announces 2026 Exam Priorities

On November 17, the SEC Division of Examinations (the “Division”) released its 2026 Fiscal Year Examination Priorities (the “2026 Priorities”)—the first announcement of exam priorities under Chairman Paul S. Atkins. In...more

UK Financial Conduct Authority Consults on Fund Tokenisation

Historically, the FCA’s position on crypto assets was consistently to repeat to consumers that “if you decide to invest in crypto then you should be prepared to lose all the money you have invested”. Suffice to say, the FCA’s...more

SEC Forms Cross-Border Task Force with Implications for Foreign Issuers, Auditors and Other Gatekeepers

On September 5, 2025, the U.S. Securities and Exchange Commission (SEC) announced the creation of a Cross-Border Task Force designed to enhance the Enforcement Division’s efforts to combat fraud involving foreign companies....more

Atkins-Led SEC Brings First Enforcement Action for Compliance Failures Under the Marketing Rule

On September 4, 2025, the U.S. Securities and Exchange Commission (SEC) brought its first enforcement action under the Marketing Rule since Chair Paul Atkins was sworn in earlier this year—charging Meridian Financial, LLC...more

Recent Developments in the Law of Federal Property Fraud: It’s a Long and Winding Road

In two recent high-profile decisions, Chastain v. United States and Johnson v. United States, the U.S. Court of Appeals for the Second Circuit reversed wire fraud convictions that were based on theories resembling insider...more

Crypto CLARITY: The Politics, Policy and Implications of Digital Assets Regulatory Framework Legislation in the 119th Congress

The strong vote in the House for the CLARITY Act sends a clear message to the Senate that there is bipartisan momentum and support for digital asset market structure legislation. However, several obstacles remain. Given the...more

DOJ Hits Play: The End of the FCPA “Pause” and Return to Enforcement

On June 9, 2025, the Deputy Attorney General issued a Memorandum detailing the administration’s new FCPA guidelines for all current and future investigations and enforcement actions. According to the Head of DOJ’s Criminal...more

Atkins-led SEC Recognizes that Conflicts of Interest must be “Material” in Complaint alleging Fraud and Breaches of Fiduciary...

SEC v. Nagler is the second enforcement action charging an investment adviser with undisclosed conflicts of interest since Chair Paul Atkins began his tenure on April 21, 2025. The Securities and Exchange Commission (SEC)...more

DOJ’s Criminal Division Turns Page on White Collar Crime—But Keeps One Foot in the Past

On May 12, 2025, the DOJ announced a new “white-collar enforcement plan” identifying new corporate enforcement priorities and aiming to promote greater focus, fairness and efficiency in prosecuting corporate misconduct. In a...more

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