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SEC and CFTC Fines for Texting Augur Billions More from DOJ

In September 2022, the SEC and CFTC fined some of the largest financial services firms in the world approximately $1.8 billion for texting. Specifically, for failing to maintain or preserve “off-channel communications” on...more

Admissions of Wrongdoing Back in Vogue: SEC Enforcement Pendulum Swings

The Securities and Exchange Commission (SEC) recently announced its intention to avoid “neither admit nor deny” settlements in some cases and instead return to an Obama-era policy requiring more individuals and companies to...more

Making Good on Its Promise: SEC Pursues Cyber Enforcement Actions Against Financial Services Companies

On August 30, the Securities and Exchange Commission (SEC) announced settled charges with several investment advisory firms and broker-dealers following email account takeovers. These settlements are the latest in a string of...more

On Cybersecurity, Grab the Low-Hanging Fruit

SEC Tells Firms to Stop Missing the Basics on Cybersecurity - The SEC’s Office of Compliance Inspections and Examinations (OCIE) reported in a recent Risk Alert that many investment advisers and broker-dealers are failing to...more

Supreme Court Casts a Wide Net with Rule 10b-5

The U.S. Supreme Court recently held that someone doesn’t need to have “made” a false or misleading statement to have primary liability under the securities fraud rules. ...more

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