Responding to a “concern” from Chief Compliance Officers (CCOs) to the purported increase in enforcement actions holding compliance personnel personally liable, the New York City Bar Association recently released a framework...more
As political leaders continue to debate how to address climate change, the SEC is poised to take (enforcement) action. In the latest example of how the Biden Administration is influencing the priorities the SEC, the agency...more
From mid-March to mid-May, the SEC received more than 4,000 tips, complaints, and referrals. This, according to one of the SEC Co-Directors of the Division of Enforcement, represented a 35% increase over the same period last...more
As we noted earlier this month, the SEC has sought to proactively combat fraud related to the coronavirus/COVID-19 pandemic and related economic crisis by suspending the trading of at least eleven different companies since...more
Steven Seagal just learned the hard way that, unlike the title of his 1988 police action movie, he is not Above the Law. Unfortunately for the prolific action movie star, the SEC took notice of his recent actions and was Out...more
Facing a 35-day government shutdown and new restrictions on the ability to recover disgorgement, it would be perfectly understandable if the SEC’s Division of Enforcement suffered a lackluster year. Nevertheless, according to...more
11/18/2019
/ Conflicts of Interest ,
Cryptocurrency ,
Digital Assets ,
Disgorgement ,
Distributed Ledger Technology (DLT) ,
Enforcement Actions ,
Kokesh v SEC ,
SCOTUS ,
Securities and Exchange Commission (SEC) ,
Share Class Selection Disclosure Initiative (SCSD) ,
Statute of Limitations ,
White Collar Crimes
The U.S. Commodity Futures Trading Commission (“CFTC”) sent a strong message to Chief Compliance Officers (“CCO”) this week when it held a CCO held accountable for lying to the National Futures Association (“NFA”) during an...more
9/19/2019
/ Administrative Proceedings ,
Bad Actors ,
CEOs ,
CFTC ,
Chief Compliance Officers ,
Commodity Exchange Act (CEA) ,
Commodity Futures Contracts ,
Enforcement Actions ,
Misappropriation ,
National Futures Association ,
Private Equity Funds