On November 22, 2024, the US Securities and Exchange Commission (SEC) released its enforcement results for fiscal year ("FY") 2024 (October 1, 2023 through September 30, 2024).1 While the next administration's approach to...more
2024 marks the final year of Gary Gensler's term as Chair of the U.S. Securities and Exchange Commission ("SEC"). The Gensler SEC has been aggressive on both the enforcement and rulemaking fronts. In response, the financial...more
12/23/2024
/ Artificial Intelligence ,
Capital Markets ,
Cryptocurrency ,
Cybersecurity ,
Disclosure Requirements ,
Enforcement ,
Enforcement Priorities ,
Financial Markets ,
Fund Managers ,
Gary Gensler ,
Insider Trading ,
Investment Management ,
Machine Learning ,
Pay-To-Play ,
Presidential Nominations ,
Regulatory Agenda ,
Regulatory Requirements ,
Reporting Requirements ,
Rulemaking Process ,
SCOTUS ,
SEC v Jarkesy ,
Securities and Exchange Commission (SEC) ,
Technology Sector ,
Trump Administration ,
Whistleblower Protection Policies
The U.S. Securities and Exchange Commission's ("SEC") Division of Enforcement has recently brought a spate of enforcement actions relating to key topics for public companies. These include enforcement actions related to...more
On May 13, 2024, FinCEN and the SEC jointly proposed a new rule that would require SEC-registered investment advisers and exempt reporting advisers to maintain written customer identification programs (CIPs). The new rule...more
5/21/2024
/ AML/CFT ,
Anti-Money Laundering ,
Asset Management ,
Bank Secrecy Act ,
Broker-Dealer ,
BSA/AML ,
Comment Period ,
FinCEN ,
Investment Adviser ,
New Rules ,
Public Comment ,
Registered Investment Advisors ,
Regulatory Reform ,
Regulatory Requirements ,
Reporting Requirements ,
Risk Assessment ,
Risk Management ,
Securities and Exchange Commission (SEC)
While there are news reports that the U.S. Securities and Exchange Commission ("SEC") is on the verge of issuing new climate related disclosure rules for public companies, the SEC's Director of the Division of Enforcement...more
On October 30, 2023, the US Securities and Exchange Commission ("SEC") announced that it filed charges against SolarWinds Corp. ("SolarWinds" or the "Company") and its Chief Information Security Officer ("CISO") in connection...more
11/15/2023
/ Breach Notification Rule ,
Chief Information Security Officer (CISO) ,
Civil Monetary Penalty ,
Cyber Attacks ,
Cybersecurity ,
Disclosure Requirements ,
Enforcement ,
Fraud ,
Information Technology ,
Initial Public Offering (IPO) ,
Injunctive Relief ,
Insurance Industry ,
Internal Controls ,
Investors ,
Material Misstatements ,
Misleading Statements ,
NIST ,
Omissions ,
Popular ,
Publicly-Traded Companies ,
Reporting Requirements ,
Sarbanes-Oxley ,
Securities Act of 1933 ,
Securities and Exchange Commission (SEC) ,
Securities Exchange Act of 1934 ,
Software ,
Vulnerability Assessments
On September 29, the US Securities and Exchange Commission ("SEC") brought its latest wave of enforcement actions related to "off-channel communications," charging 10 additional firms with failing to maintain employee...more
11/1/2023
/ Broker-Dealer ,
Compliance ,
Enforcement Actions ,
Investment Adviser ,
Investment Advisers Act of 1940 ,
Mobile Devices ,
Record Retention ,
Regular Business Communications ,
Reporting Requirements ,
Securities and Exchange Commission (SEC) ,
Securities Exchange Act ,
Securities Regulation ,
Self-Reporting