The Justice Insiders Podcast - The Ever-Expanding Net: Corporate Compliance in an Era of Increasing Trade Sanctions and Restrictions
False Claims Act Insights - Are All Healthcare “Kickbacks” Subject to FCA Liability?
Episode 333 -- The Boeing Proposed Plea Agreement
DOJ’s New Self-Disclosure Policy and Corporate Whistleblower Awards Pilot Program
False Claims Act Insights - Assessing the Fallout from a Thermonuclear FCA Verdict
FCPA Survival Guide - Step 8 - Investing in Compliance
Exploring the AI and Crypto Intersection
The Justice Insiders Podcast: Jarkesy’s Implications for the Administrative State
The Presumption of Innocence Podcast: Episode 41 - The Dynamics of Decision-Making: Psychology and the Criminal Justice System
INTERPOL and Child Kidnapping Cases. What are INTERPOL’s Abilities and Limitations?
False Claims Act Insights - Eureka! Government Investigators Seek Out Research Misconduct
The Justice Insiders Podcast - AI-Washing: Everything Old Is New Again
The CFPB and State AGs Act Jointly Against Online Educational Company
Will the U.S. Have a GDPR? With Rachael Ormiston of Osano
Episode 328 -- Sanctions Enforcement Risks and Redlines
FCPA Survival Guide: Step 3 - Extensive Remediation
Episode 324 -- Third-Party Risks and Sanctions Compliance
Compliance Tip of the Day – Compliance Lessons from the Albemarle FCPA Enforcement Action
The Presumption of Innocence Podcast: Episode 38 - A Blueprint for Compliance: The Fraud Pentagon Theory
Episode 323 - Carlos Villagran Discusses Rebuilding a Corporate Culture After a Crisis
The Securities and Exchange Commission (SEC) continues to investigate companies for including language in their employment and separation agreements or retail client settlement agreements that potentially discourages...more
According to recent reports, two U.S. multinational financial technology companies have integrated Ethereum Name Service (ENS), a decentralized naming system built on the Ethereum blockchain, into their payment platforms....more
The U.S. Securities and Exchange Commission (SEC) has announced two settled charges involving alleged violations of Rule 206(4)-2 under the Investment Advisers Act of 1940 (Advisers Act), known as the “Custody Rule.” These...more
On September 4, the Securities and Exchange Commission (SEC) issued an order against three investment adviser firms for violating the whistleblower protections of Rule 21F-17(a) under the Securities Exchange Act of 1934. This...more
More Flack on WhatsApp, Hypothetical Performance SmackDown, A Timely Warning on the Pay-to-Play Rule, and Updates to Qualifying Venture Capital Fund Exemption - This month's big news from the SEC was more piggy-bank breaking...more
On August 12, the SEC issued published a settled enforcement action order against a broker-dealer for failing to monitor, investigate, and file Suspicious Activity Reports (SARs) between March 2020 and May 2023, violating...more
On August 14, 2024 the U.S. Securities and Exchange Commission (the “SEC”) announced settled charges against 26 SEC-registered investment advisers, broker-dealers and dually-registered broker-dealers and investment advisers...more
SEC's and CFTC's Enforcement Actions Against Multiple Firms - In its continued pursuit of rooting out and penalizing broker-dealers and investment advisers for their failure to prevent unapproved communication methods, the...more
Two and a half years after the first major settlement with some of the world’s largest financial institutions, the Securities and Exchange Commission (SEC) and the Commodity Futures Trading Commission (CFTC) persist in their...more
Each month, we publish a roundup of the most important SEC enforcement developments for busy in-house lawyers and compliance professionals. This month, we examine: •Judge Paul Engelmayer’s decision on defendants’ motion to...more
The Securities and Exchange Commission (SEC) announced charges against 26 broker-dealers, investment advisers, and dually-registered firms for widespread and longstanding failures to maintain and preserve electronic...more
Recently, the SEC released its complaint against a digital platform that acted as an unregistered broker and seller of crypto-asset securities transactions. The SEC alleges that since 2020 the platform brokered over 36...more
The SEC has charged a leading developer on the Ethereum blockchain with engaging in the unregistered offer and sale of certain securities through a “liquid staking” program and with failing to register as a broker in...more
On May 15, 2024, the SEC announced it would make amendments to Regulation S-P (Reg S-P). This will be the first amendment to the regulation since its adoption 24 years ago in 2000. The regulation focuses on how institutions...more
Who may be interested: Investment Companies; Investment Advisers; Broker-Dealers; Transfer Agents - The SEC adopted amendments to Regulation S-P imposing new data privacy and security requirements on broker-dealers,...more
The Securities and Exchange Commission (“SEC”) has announced the adoption of amendments to Regulation S-P (“Amendments”) to modernize and enhance the rules that govern the treatment of consumers’ nonpublic personal...more
In March 2024, the SEC announced that it settled two cases against investment advisers Delphia (USA) Inc. and Global Predictions Inc. for making false and misleading statements about their purported use of artificial...more
Crypto and Web3 Firms Announce Fintech Integrations - A major U.S. fintech firm recently announced a product integration with MoonPay, a Web3 infrastructure company, “that allows MoonPay users in the U.S. to seamlessly buy...more
Welcome to the Regulatory Roundup. Each month, Eversheds Sutherland Investment Services attorneys review significant regulatory developments (including notable rulemakings and guidance from securities regulators) from the...more
Earlier this year, the SEC, NASAA, and FINRA issued an Investor Alert cautioning investors about the rise of investment fraud involving artificial intelligence (AI) and other emerging technologies. The overarching concern:...more
The SEC’s enforcement action sends a clear message that the Commission intends to enforce “off-channel communication” violations against private fund advisers that are not affiliated with a broker-dealer....more
The Securities and Exchange Commission (“SEC”) and the Financial Industry Regulatory Authority (“FINRA”) have, in two separate recent settled enforcement actions involving off-channel communications (“OCC”), imposed fine...more
With political campaign activity ramping up as the fall elections approach, the Securities and Exchange Commission (SEC) has indicated it will continue stringent enforcement of Investment Advisers Act Rule 206(4)-5 (the...more
Over the last several years, the Securities and Exchange Commission (“SEC”) has been laser-focused on the use of so-called “off-channel communications” in the financial services industry. On the theory that employees’ use of...more
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