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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

Supreme Court Narrows Federal Bribery Statute That Applies to State and Local Officials

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

Second Circuit Holds That Syndicated Term Loans Are Not Securities

Key Points - On August 24, 2023, a three-judge panel of the 2nd Circuit unanimously held that the syndicated term loans at issue were not “securities” under the test articulated by the Supreme Court in Reves v. Ernst &...more

Split Court Decision on Whether a Token Is a Security in SEC v. Ripple Labs

Key Points - A judge in the Southern District of New York recently held that (i) the crypto asset XRP is not, on its own, a security and, (ii) as a result, the determination of whether an offer or sale of XRP required SEC...more

Supreme Court and 1st Circuit Significantly Curtail Scope of Federal Property Fraud Statutes

Key Points- In two landmark decisions, the Supreme Court and the 1st Circuit significantly pared back the scope of the federal mail and wire fraud statutes. In Ciminelli v. United States, a political corruption case, the...more

Blaszczak II: 2nd Circuit Reverses Course and Overturns Insider Trading Convictions

Key Points - In the wake of the Supreme Court’s “Bridgegate” decision in Kelly v. United States, a divided panel in the 2nd Circuit reversed its prior decision in United States v. Blaszczak, and held that a federal...more

Liu v. SEC – Supreme Court Establishes Important Limitations on SEC Disgorgement

- In Liu v. SEC, No. 18-1501, the Supreme Court upheld the SEC’s ability to obtain disgorgement as a form of equitable relief in civil actions in federal court, pursuant to 15 U.S.C. § 78u(d)(5). - However, the Court...more

Supreme Court Overturns ‘Bridgegate’ Convictions: Decision Will Have Ramifications for Traditional Business-Crime Prosecutions

- The Supreme Court has unanimously reversed the convictions of the state officials in the “Bridgegate” scandal. - This decision will have broader implications beyond the context of political corruption and will also...more

Liu v. SEC: Supreme Court Agrees to Hear Challenge to SEC’s Ability to Obtain Disgorgement

• The Supreme Court will review whether the SEC has the authority to obtain disgorgement in actions to enforce the federal securities laws. • Since the Supreme Court’s decision in Kokesh v. SEC, 137 S. Ct. 1635 (2017),...more

U.S. Supreme Court: Disseminators of False Statements with Intent to Defraud can be Held Liable Under Securities Exchange Act Rule...

• The United States Supreme Court held that a disseminator of a false statement with intent to defraud can be held liable under subsections (a) and (c) of Rule 10b-5, §10(b) of the Exchange Act and §17(a)(1) of the Securities...more

Government Agencies Face Uncertainty After Supreme Court Rules That SEC ALJs Must Be Appointed

• SEC ALJs are “Officers of the United States” within the meaning of the Appointments Clause and therefore must be appointed directly by the SEC. The Court’s decision may permit litigants in prior and pending administrative...more

The Supreme Court Holds that State Courts Have Jurisdiction over Certain Securities Class Actions

• The United States Supreme Court held that certain securities class actions affecting issuer defendants may be brought in state court and may not be removed to federal court. • The decision will likely extend or expand...more

Supreme Court Limits Whistleblower Protections Under Dodd-Frank

• Whistleblower protections for securities violations in Dodd-Frank extend to only employees who report violations to the SEC. • Applying the plain language of the statute’s definition of “whistleblower,” limiting the...more

Administrative Proceedings in Peril? Supreme Court Grants Certiorari in Lucia v. SEC

• On January 12, 2018, the Supreme Court granted certiorari in Lucia v. SEC, to resolve a circuit split over whether the SEC’s administrative law judges serve in violation of the Appointments Clause of the Constitution. •...more

Kokesh v. SEC: Supreme Court Reins in SEC’s Powerful Disgorgement Remedy

This week, the Supreme Court in Kokesh v. SEC unanimously held that the Securities and Exchange Commission’s (SEC) equitable disgorgement remedy is subject to a five-year statute of limitations because it is a “penalty”...more

United States v. Salman: Supreme Court Reaffirms “Friends With Benefits” Test In Insider Trading Cases

On December 6, 2016, in an opinion written by Justice Alito, the Supreme Court unanimously affirmed the Ninth Circuit’s decision in Salman v. United States, a closely-watched insider trading tipping case. Salman builds upon...more

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