Machine Learning for Environments with Bad Actors
Jenny Radcliffe on People Hacking
AFSA Extra Credit Podcast: Navigating Advertising During COVID-19
Compliance Perspectives: The Right Kind of Wrong
JOBS Act Implementation Regulations
Last week, the National Counterintelligence and Security Center (“NCSC”), the Office of Economic Security and Emerging Technologies (“OESET”) and other coordinating government agencies issued a warning to U.S. venture...more
On September 12, the U.S. Securities and Exchange Commission (SEC) Chair Gary Gensler testified before the U.S. Senate Committee on Banking, Housing, and Urban Affairs. His testimony emphasized that market growth combined...more
Unscrupulous actors may make misleading statements, use deceptive behavior, or produce falsified statements or documents to induce you to invest in what you are led to believe is a legitimate business opportunity – from real...more
As the cannabis industry continues to evolve and generate capital raising and investment opportunities, the SEC Division of Enforcement will continue to closely keep watch and target the bad actors that new market...more
After an evening checking out my various high school and college yearbooks for any troublesome content, and checking Mom’s photo albums (I’m good on the yearbooks, but there were a couple cowboy and Indian pics from when I...more
Companies seeking to expand operations often face numerous challenges. One such challenge is raising the capital necessary to make such an expansion possible. When a company sees an expansion opportunity but does not have the...more
When looking to raise capital, broker-dealer compliance may not be at the forefront of a private fund manager’s mind. However, engaging individuals (including the fund manager’s employees) or firms to identify, introduce or...more
What is Crowdfunding? Crowdfunding is a marketing tool that businesses use to obtain capital from a large number of individuals, typically over the Internet....more
The SEC has been thinking harder before waiving automatic disqualifications that the federal securities laws and regulations impose on so-called "bad actors." Without such waivers, companies may be barred from, among...more
The staff of the SEC’s Division of Corporation Finance posted additional Compliance and Disclosure Interpretations (see Questions 260.14 through 260.27) to the SEC website that address the “bad actor” disqualification...more
Shortly after the Securities and Exchange Commission (SEC) adopted the final rule relaxing the prohibition against general solicitation in connection with offerings made pursuant to new Rule 506(c) and Rule 144A, we provided...more
Until recently, U.S. offerors and others had to make offerings of EB-5 project investments solely offshore in order to benefit from Regulation S, an exclusion from registration requirements. The offerors had to exclude...more
The Jackson Five had it wrong. Under the SEC’s recently adopted Rule 506(d), one bad actor can spoil the whole bunch. To some extent issuers can exercise some control over who becomes or remains a covered persons. However,...more