News & Analysis as of

Failure-to-File Enforcement Actions

Foster Garvey PC

Updates to the Corporate Transparency Act Are Coming in at a Rapid Fire – Treasury Issued a Huge Change in the Trajectory of the...

Foster Garvey PC on

If you feel punch-drunk from the rapid-fire updates to the Corporate Transparency Act (“CTA”), you are not alone. It is hard to keep up with the madness surrounding this law. Hoping not to stupefy readers, I will address...more

Foster Garvey PC

FinCEN Delivers Some Good News About Its Enforcement of the Corporate Transparency Act

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On Thursday, February 27, 2025, FinCEN announced that it will not issue any penalties or pursue enforcement action against reporting companies for the mere failure to meet the current filing deadlines. That news for many is...more

Bowditch & Dewey

Corporate Transparency Act – Yes, it’s Back, but no Fines or Penalties for Now

Bowditch & Dewey on

On February 27, 2025, in a move to comply with the Treasury’s commitment to reducing regulatory burdens on businesses, FinCEN announced that it will not impose fines or penalties or take other enforcement actions against any...more

Holland & Knight LLP

3 French Hens? No. SEC Presses Enforcement on Insider Trading, Shadow Trading, Reg FD

Holland & Knight LLP on

The SEC did not take its foot off the pedal in fiscal year (FY) 2024 when it came to prosecuting insider trading. In the third installment of Season's Readings, we consider several recent actions in which the agency secured...more

Latham & Watkins LLP

Recent Developments for Directors - November 2024

Latham & Watkins LLP on

SEC Penalizes Director for Misleading D&O Questionnaire Response - The SEC recently brought an enforcement action against a director for causing violations of the proxy rules by failing to disclose a close personal...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

California Civil Rights Department’s Pay Data Enforcement Action Highlights Risks Related to Failures to File Required Reports

As the 2023 California pay data reporting cycle begins, a look at the California Civil Rights Department’s (CRD) recent pay data reporting enforcement actions provides a helpful reminder of the potential risk that exists for...more

Ballard Spahr LLP

FinCEN Issues $15 Million Dollar Civil Penalty Against Shinhan Bank America for Alleged Failure to Implement and Maintain...

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On September 29, the Financial Crimes Enforcement Network (“FinCEN”) entered into a consent order with Shinhan Bank America (“SHBA”), which imposed a $15 million dollar civil penalty against SHBA for allegedly willfully...more

Morrison & Foerster LLP

Top 5 SEC Developments for July 2023

In order to provide an overview for busy in-house counsel and compliance professionals, we summarize below some of the most important SEC enforcement developments from the past month, with links to primary resources. This...more

Wiley Rein LLP

CFIUS Releases First-Ever Enforcement and Penalty Guidelines

Wiley Rein LLP on

On October 20, 2022, the Department of the Treasury (Treasury), which chairs the Committee on Foreign Investment in the United States (CFIUS), released the first-ever CFIUS Enforcement and Penalty Guidelines (the Guidelines)....more

Goodwin

SEC Penalizes 12 Additional BDs and IAs with CRS Failures

Goodwin on

On February 15, 2022, the SEC announced settlements with 12 broker-dealers and investment advisers for failing to satisfy their Form CRS obligations. These settlements come on the heels of 27 settlements last year for similar...more

Dechert LLP

Significant fines imposed in HSR failure to file actions

Dechert LLP on

On December 22, 2021, the Federal Trade Commission (FTC) and Antitrust Division of the Department of Justice (DOJ) announced that they had entered into settlements with Clarence L. Werner and Biglari Holdings Inc. (Biglari)...more

Ballard Spahr LLP

Court Decision Reinforces SAR Obligations of Penny Stock Clearing Brokers

Ballard Spahr LLP on

Second Post in a Two-Part Series - Opinion Stresses Importance of Narrative Sections and Supporting Documentation for SARs - In our first post in this series, we discussed the Securities and Exchange Commission’s...more

Skadden, Arps, Slate, Meagher & Flom LLP

Failure to Report Adverse Events Results in Criminal Misbranding Settlement and Individual Liability

On December 10, 2018, Olympus Medical Systems Corporation and a former quality manager at the company pleaded guilty to introducing misbranded medical devices into interstate commerce in violation of the Federal Food, Drug...more

Stinson - Corporate & Securities Law Blog

Elon Musk, Twitter and Disclosure Controls and Procedures

In perhaps the fastest moving SEC enforcement action of all time, the SEC charged Elon Musk with securities fraud on September 27, 2018 after settlement agreements reportedly fell apart....more

Stinson - Corporate & Securities Law Blog

SEC Charges 13 Private Fund Advisers for Failure to File Form PF

The SEC announced settlements with 13 registered private fund investment advisers who repeatedly failed to provide required information that the agency uses to monitor risk. ...more

A&O Shearman

SEC And FINRA Fine Broker-Dealer, CEO, And Compliance Officer For Failing To File Suspicious Activity Reports

A&O Shearman on

On March 28, 2018, the Securities and Exchange Commission (“SEC”) instituted settled administrative proceedings against broker-dealer Aegis Capital Corporation (“Aegis”), its founder and Chief Executive Officer (“CEO”), and...more

Perkins Coie

Hart-Scott-Rodino Annual Report for Fiscal Year 2016: Increases in Filings and Second Requests, Impact on Executive Stock...

Perkins Coie on

The Hart-Scott-Rodino Annual Report Fiscal Year 2016 , published last year by the Federal Trade Commission (FTC) and the U.S. Department of Justice (DOJ), summarizes FTC and DOJ actions conducted under the Hart-Scott-Rodino...more

McDermott Will & Emery

Flurry of Antitrust Merger Enforcement Actions as Obama Presidency Comes to a Close

The Federal Trade Commission (FTC) and Antitrust Division of the Department of Justice (DOJ) announced several antitrust enforcement actions in advance of the inauguration of President Trump, including settlements for...more

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