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
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
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
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
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
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
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
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
1/28/2026
/ Biotechnology ,
Enforcement Actions ,
Insider Trading ,
Market Manipulation ,
Material Nonpublic Information ,
Pharmaceutical Industry ,
Pump and Dump ,
Rule 10b-5 ,
Securities Act of 1933 ,
Securities and Exchange Commission (SEC) ,
Securities Exchange Act of 1934
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
At a White House press briefing on Thursday, January 8, 2026, Vice President JD Vance outlined a nationwide fraud enforcement initiative anchored by a new Senate-confirmed Department of Justice (DOJ) leadership position that...more
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
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
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
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
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
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
On March 20, 2025, the United Kingdom, France and Switzerland jointly announced the formation of a new International Anti-Corruption Prosecutorial Taskforce (the “Task Force”) aimed at strengthening cross-border collaboration...more
5/13/2025
/ Anti-Corruption ,
Corporate Counsel ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Executive Orders ,
Foreign Corrupt Practices Act (FCPA) ,
France ,
Government Agencies ,
Switzerland ,
UK
On February 25, 2025, the U.S. Commodity Futures Trading Commission (CFTC) released an enforcement advisory regarding the impact of self-reporting, cooperation and remediation in enforcement cases (the “Enforcement...more
UPDATE: President Signs Executive Order Directing DOJ to Pause All FCPA Enforcement for 180 Days - On February 10, 2025, President Trump issued an Executive Order directing the U.S. Department of Justice (DOJ) to pause all...more
On June 26, 2024, the U.S. Supreme Court held 6-3 in Snyder v. United States that a federal statute, 18 U.S.C. § 666(a)(1)(B), does not criminalize “gratuities” to state and local officials—i.e., payments made to those...more
On Friday, April 5, 2024, a San Francisco jury found the defendant liable in SEC v. Panuwat, the closely watched litigated enforcement action brought by the U.S. Securities and Exchange Commission (SEC) relating to so-called...more
On April 3, 2024, the U.S. Securities and Exchange Commission (SEC) announced its first enforcement action against a registered investment adviser (RIA) with no ties to a broker-dealer regarding so-called “off-channel”...more
4/10/2024
/ Broker-Dealer ,
Electronic Communications ,
Enforcement Actions ,
Fund Managers ,
Investigations ,
Investment Adviser ,
Investment Management ,
Recordkeeping Requirements ,
Registered Investment Advisors ,
Securities and Exchange Commission (SEC) ,
Securities Regulation ,
Securities Violations
Key Points - In a thorough decision, a federal district judge in New York largely denied Coinbase’s motion for judgment on the pleadings in a case brought by the SEC. Applying the plaintiff-friendly standards required at the...more
Last month, the United Kingdom Financial Conduct Authority (FCA) announced that it is considering new procedures under which it would publicly identify firms that are under investigation as soon as the investigation has been...more
4/1/2024
/ Cross-Border ,
Department of Justice (DOJ) ,
Disclosure Requirements ,
Enforcement ,
Financial Conduct Authority (FCA) ,
FSMA ,
Investigations ,
Notice Requirements ,
Securities and Exchange Commission (SEC) ,
UK ,
Willful Misconduct
On February 20, 2024, the U.S. Supreme Court declined to hear an appeal brought by the trustee of the Millennium Lender Claim Trust challenging the U.S. Court of Appeals for the 2nd Circuit’s August 2023 decision, in which...more