On April 7, 2024, the United States District Court for the District of Connecticut approved the Securities and Exchange Commission’s request to dismiss its action against a hedge fund manager for the manager’s alleged failure...more
Last week President Trump signed an Executive Order pausing enforcement of the nation’s most robust anti-bribery statute, the Foreign Corrupt Practices Act (“FCPA”). The EO seeks a complete overhaul of the FCPA enforcement...more
2/14/2025
/ Anti-Bribery ,
Attorney General ,
Cartels ,
Compliance ,
Corporate Governance ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Foreign Corrupt Practices Act (FCPA) ,
National Security ,
Securities and Exchange Commission (SEC) ,
Significant Transnational Criminal Organization ,
UK
Summary of the Recent SEC Actions -
On August 8, 2023, in yet another set of enforcement actions in the space, the U.S. Securities and Exchange Commission (the “SEC”) settled charges against ten broker-dealers and a dually...more
DOJ Promotes Compliance Through Compensation and Clawback Programs (3.2.2023):
• The DOJ announced corporate criminal resolutions will now include a requirement that companies implement a compensation and bonus scheme...more
3/10/2023
/ 10b5-1 Plans ,
Bank Fraud ,
CFTC ,
Clawbacks ,
Compensation ,
Compliance ,
Consumer Financial Protection Bureau (CFPB) ,
Cryptocurrency ,
Department of Justice (DOJ) ,
Federal Trade Commission (FTC) ,
Financial Industry Regulatory Authority (FINRA) ,
Insider Trading ,
Securities and Exchange Commission (SEC) ,
Self-Disclosure Requirements
On March 1, 2023, the U.S. Department of Justice (“DOJ”) unsealed an indictment charging Terren S. Peizer, the CEO and Chairman of the Board of Directors of Ontrak Inc., a publicly traded health care company, with engaging in...more
On September 20th, 2022, the Securities and Exchange Commission (“Commission”) entered a settled order (“Order”) against the wealth management arm of a global financial services firm (“Firm”) for its failure to protect...more
On September 27, 2022, the Securities and Exchange Commission (“Commission”) entered into a series of settled orders (“Orders”) against 15 broker-dealers and one affiliated investment adviser for widespread failures by the...more
10/4/2022
/ Broker-Dealer ,
Compliance ,
Electronic Communications ,
Investment Adviser ,
Investment Advisers Act of 1940 ,
Penalties ,
Policies and Procedures ,
Recordkeeping Requirements ,
Securities ,
Securities and Exchange Commission (SEC) ,
Securities Exchange Act of 1934
On June 15, 2022, the Securities and Exchange Commission (“SEC”) filed a complaint against California-based broker-dealer Western International Securities, Inc. (“Western”) alleging violations of Regulation Best Interest...more
6/29/2022
/ Best Interest Standard ,
Broker-Dealer ,
Enforcement Actions ,
Fiduciary Duty ,
Financial Services Industry ,
Investment ,
Investment Adviser ,
Investment Management ,
Regulation Best Interest ,
Regulation BI ,
Retail Installment Sales Contracts ,
Retail Investors ,
Securities and Exchange Commission (SEC) ,
Securities Regulation ,
Securities Transactions ,
Securities Violations ,
Standard of Conduct