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Insider Trading Publicly-Traded Companies

Bradley Arant Boult Cummings LLP

In First Public Speech, SEC’s Director of Enforcement Sheds Light on Priorities and Process

Former judge Margaret Ryan became the Director of the Securities and Exchange Commission’s Division of Enforcement in September 2025. But it was not until last week, in February 2026, that she made her first public speech as...more

Herbert Smith Freehills Kramer

NY Attorney General brings action against former Emergent BioSolutions CEO

On January 15, 2026, Letitia James, the New York attorney general (NY Attorney General), filed a complaint against Robert Kramer, the former CEO of Emergent BioSolutions Inc., alleging insider trading in violation of the...more

Foley & Lardner LLP

N.Y. Attorney General Brings Insider Trading Case

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On January 15, 2026, the Attorney General of the State of New York (NY A.G.) filed suit against Roger G. Kramer, the former CEO of Emergent BioSolutions, Inc., accusing him of insider trading for selling his shares in the...more

Haynes Boone

SEC Enforcement Highlights Fiscal Year 2025

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Shifts in SEC enforcement are typical with new presidential administrations, particularly with a change in the political party. But never have those shifts been as dramatic as those we witnessed in fiscal year 2025. Through...more

Baker Botts L.L.P.

Prosecuting Like Its 2007? New York Attorney General Brings Martin Act Insider Trading Action Against Former Public-Company CEO

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Over the last several months, there have been a number of reports about a perceived drop-off in enforcement activity by the U.S. Securities and Exchange Commission, including in the area of insider trading....more

McDermott Will & Schulte

Foreign private issuer officers and directors required to file with the SEC under Section 16(a) of the Securities Exchange Act of...

On December 18, 2025, the Holding Foreign Insiders Accountable Act (the Act) was enacted as part of the 2026 National Defense Authorization Act. Effective March 18, 2026, the Act eliminates an exemption from the reporting...more

Morrison & Foerster LLP

Biopharmaceutical Consultant Faces Criminal and Civil Insider Trading Charges

In case there was any doubt, insider trading enforcement—including DOJ criminal and SEC civil charges—remains a priority to kick off the new year. Last week, the U.S. Attorney’s Office for the District of Massachusetts...more

A&O Shearman

Out of sight, not out of scope: UK FCA fines and bans individual for insider dealing

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The UK FCA has fined a capital markets adviser to an energy company £100,281 – and banned him from working in financial services – for insider dealing. The action illustrates the comparatively low threshold for what may...more

McGuireWoods LLP

McGuireWoods Quarterly Securities & Capital Markets Update

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Welcome to the inaugural McGuireWoods’ Quarterly Securities & Capital Markets Update. Each edition will review important securities law developments from the previous quarter and alert readers of significant considerations...more

Jones Day

SEC Enforcement in Financial Reporting and Disclosure: Fiscal 2025 Year-End Update

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Financial reporting and disclosure enforcement is a perennial priority for the U.S. Securities and Exchange Commission (“SEC”), but the change in presidential administrations in January 2025 ushered in a potentially new...more

Cooley LLP

What to Expect Now from the SEC’s Enforcement Division

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Here’s the intro from this entry on Cooley’s “Securities Litigation + Enforcement” blog penned by Luke Cadigan, Tejal Shah, Elizabeth Skey, Samanta Kirby and Bingxin Wu: “When Paul Atkins became the new chairman of the...more

Holland & Knight LLP

SEC Enforcement 2025 Year in Review

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In this third installment of Season's Readings, we button up our winter jackets and examine the transformative Year of Enforcement that was 2025. The past year has been one of significant transition at the SEC, with new...more

Cooley LLP

SEC Public Companies Enforcement: FY 2025 Review and What to Expect in 2026

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When Paul Atkins became the new chairman of the Securities and Exchange Commission (SEC) in April 2025, the market expected enforcement actions against public companies to decrease....more

Skadden, Arps, Slate, Meagher & Flom LLP

Foreign Private Issuers’ D&Os Will No Longer Be Exempt From Section 16(a) Insider Reporting Obligations

On December 18, 2025, as part of the FY 2026 National Defense Authorization Act, the Holding Foreign Insiders Accountable Act (HFIAA) was signed into law....more

Ropes & Gray LLP

Directors and Officers of FPIs Required to Begin Publicly Reporting Equity Ownership, Awards, and Transactions on March 18, 2026

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Beginning on March 18, 2026, directors and officers of foreign private issuers (“FPIs”) with equity securities registered under the Securities Exchange Act of 1934 (the “Exchange Act”) will be required to publicly file...more

Mintz - Securities & Capital Markets...

Section 16 Insider Reporting to Apply to Foreign Private Issuers Beginning March 18, 2026

Effective March 18, 2026, directors and officers of U.S.-listed companies that qualify as foreign private issuers (FPIs) will be required to publicly report their equity holdings and transactions pursuant to Section 16(a) of...more

Tarter Krinsky & Drogin LLP

What's New for 2025 SEC Filings

As public reporting companies gear up for their 2025 SEC annual reports and proxy statements, most of the SEC’s recent disclosure rules are already in place. But a few new requirements and first-time milestones will apply to...more

Wilson Sonsini Goodrich & Rosati

Insider Trading Policies: A Survey of the SV150

Wilson Sonsini is pleased to present Insider Trading Policies: A Survey of the SV150, which analyzes the insider trading policies of Silicon Valley’s largest public companies....more

Herbert Smith Freehills Kramer

UK Public M&A Monthly Activity Update: October 2025

In October 2025, there were three Rule 2.7 announcements made across the UK public M&A market and five further possible offers announced....more

White & Case LLP

Insider Trading Policies: A Survey of Public Company Policy Terms

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White & Case’s US Public Company Advisory Group has conducted its second annual survey of publicly filed insider trading policies to assess trends with respect to insider trading policy terms. Calendar-year end public...more

Venable LLP

Trading in the Shadows: Insider Trading Policies Post-Panuwat

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"Shadow trading" refers to the use of material, nonpublic information (MNPI) about one company to trade in the securities of a different, "economically linked" company, such as a competitor or business partner. ...more

Saul Ewing LLP

Public Companies Quarterly Update (Q2 2025)

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Welcome to Saul Ewing's Public Companies Quarterly Update series. Our intent is to, on a quarterly basis, highlight important legal developments of which we think public companies should be aware....more

BCLP

Proceed at Your Own Risk: Steps to Protect Confidential Information and Public Disclosures

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Public companies regularly face challenges in protecting confidential information relating to material announcements of corporate developments as well as financial results and other events. For example, recently, the U.S....more

Akerman LLP

First-Ever Prosecution for Sales Under Rule 10b5-1 Trading Plan

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Executive Sentenced to 42 Months in Prison - Company insiders rely upon Rule 10b5-1 trading plans to sell stock pursuant to predetermined trades, allowing them to later trade securities even though they may be in...more

Cooley LLP

Don’t Forget to Coordinate Your ‘EDGAR Next’ Enrollment for Mutual Insiders!

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We’ve blogged multiple times about how you should prepare to transition to the SEC’s new “EDGAR Next” platform (here’s our latest post). We are now in that transition period where some companies are voluntarily enrolling in...more

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