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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

The European Response to DOJ’s FCPA Enforcement “Pause”

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

CFTC Acting Chair Caroline D. Pham Announces CFTC’s 30-Day Enforcement Sprint

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

CryptoLink - January 2025 Updates

Both the CFTC and SEC have new Acting Chairs, who are known to be crypto advocates, with Mark Uyeda being appointed Acting Chair of the SEC, taking over from Gary Gensler, while Caroline D. Pham has assumed the role of Acting...more

Analyzing the Attorney General’s FCPA Enforcement Shift

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

“Under the Wire” E-Comms Settlements: More Confusion Than Closure

On January 13, 2025, the U.S. Securities and Exchange Commission announced settled enforcement actions with five registered investment advisers for failing to maintain and preserve internal electronic communications. These...more

CryptoLink - December 2024 Updates

CryptoLink is a compilation of news stories published by outside organizations. Akin aggregates the stories, but the information contained in them does not necessarily represent the beliefs or opinions of the firm. Akin's...more

CryptoLink - July 2024 Updates

CryptoLink is a compilation of news stories published by outside organizations. Akin aggregates the stories, but the information contained in them does not necessarily represent the beliefs or opinions of the firm. Akin's...more

“Round 2” of Marketing Rule Enforcement Actions — Focus on Hypothetical Performance

On April 12, 2024, the U.S. Securities and Exchange Commission imposed fines and other sanctions on five registered investment advisers (RIAs) for violations of the Investment Adviser Marketing Rule (Rule 206(4)-1), which has...more

The SEC Wins ‘Shadow Insider Trading’ Trial

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

SEC Announces First Off-Channel Communications Enforcement Action Against a Standalone Private Fund Manager

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

CryptoLink - February 2024 Updates

CryptoLink is a compilation of news stories published by outside organizations. Akin aggregates the stories, but the information contained in them does not necessarily represent the beliefs or opinions of the firm. Akin's...more

CryptoLink - December 2023 Updates

On the one hand, the year ended where it began. The legislation on stabelecoins and market structure that would provide a regulatory framework for digital assets has still not been enacted into law. And Securities and...more

SEC Turning Up the Heat: SolarWinds and Its CISO Charged with Fraud Regarding Cyber-related Disclosures

Key Takeaways - With the SolarWinds enforcement action, the SEC continues to ratchet up its enforcement against companies that fail to properly disclose their cybersecurity incidents and risks. By naming the SolarWinds CISO...more

CryptoLink - September 2023 Updates

CryptoLink is a compilation of news stories published by outside organizations. Akin aggregates these stories, but the information contained in them does not necessarily represent the beliefs or opinions of the firm. Akin's...more

The SEC’s Second NFT Enforcement Action: SEC v. Stoner Cats 2

Key Point - Just over two weeks after the SEC announced the settlement of its first NFT enforcement action against Impact Theory, on September 13, 2023, the SEC announced its second NFT enforcement action against SC2, the...more

CryptoLink - August 2023 Updates

CryptoLink is a compilation of news stories published by outside organizations. Akin aggregates these stories, but the information contained in them does not necessarily represent the beliefs or opinions of the firm. Akin's...more

The SEC and FCA: A Pond, 362 Investigations and $4 Billion in Penalties Apart

No financial services firm or professional welcomes an investigation by a regulator, let alone enforcement action. Each investigation proceeds differently depending on the target of the investigation, the subject matter and...more

Judges in the Southern District of New York Divided on Whether a Token Is a Security: SEC v. Terraform Labs and SEC v. Ripple Labs

Key Point - Just shy of three weeks after Judge Torres held that the digital asset XRP is not itself a security,1 Judge Rakoff held that the SEC had adequately pled that certain digital assets, such as the UST and LUNA...more

“When you are a hammer, the world is a nail” – SEC and PCAOB Senior Staff Signal Increased SEC and PCAOB Gatekeeper Enforcement

Key Points - SEC Enforcement and PCAOB Enforcement both are pursuing more significant sanctions against auditors, particularly with respect to civil money penalties. Expect 2023 enforcement against auditors to focus...more

CryptoLink - May 2023

Washington is in a period of closely divided government. The Democrats have the White House; the Republicans have a bare majority in the House; and Democrats have a bare majority in the Senate. In practice, this means policy...more

Federal Agency Settlements with Wells Fargo Illustrate Sanctions Risks Involving IT Systems

Key Points - On March 30, 2023, OFAC announced a settlement agreement with Wells Fargo for 124 apparent violations of three different sanctions programs (Iran, Syria and Sudan), all related to a legacy Wachovia Bank...more

New DOJ Focus on Executive Compensation in Resolving Criminal Investigations

Key Points - The DOJ recently announced several policy updates tethering resolution of criminal investigations to a company’s compensation and bonus programs. These updates include executive compensation focused...more

CryptoLink - December 2022

This December issue of Crypto Link covers the significant developments surrounding FTX Trading Ltd. (FTX), including its bankruptcy filing and the charges against and arrest of its CEO, Samuel Bankman-Fried. In the midst of...more

Crypto Link - November 2022

This edition of CryptoLink follows the 2022 U.S. midterm elections, and lawmakers in Congress are now outlining ambitious agenda priorities for next Congress, putting digital assets near the top of the list. Following the FTX...more

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