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Insider Trading Securities and Exchange Commission (SEC)

Jones Day

IOSCO Report Provides Guidance that Can Help Dealers Avoid Insider Trading Scrutiny

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Both the Financial Industry Regulatory Authority ("FINRA") and the National Futures Association ("NFA") have implemented rules prohibiting the practice of "frontrunning." Criminal prosecutors and financial regulators have...more

Perkins Coie

Securities Enforcement Forum New York 2026: Shifting Priorities and Emerging Risks

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Key Takeaways - Prediction markets are squarely in the DOJ, the SEC, and the Commodity Futures Trading Commission’s (CFTC) sights, so fraud and manipulation will be prosecuted, and CFTC rulemaking on event contracts is...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

Secretariat

The Evolving SEC Enforcement Landscape: Trends for 2026

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Enforcement activity and guidance from 2025 under Chairman Paul Atkins provide important context for understanding where the SEC is focusing its attention in 2026. Regulators and practitioners highlighted these priorities at...more

Morgan Lewis

Securities Enforcement Roundup – January 2026

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In this issue of our monthly Securities Enforcement Roundup, we highlight top securities enforcement developments from January 2026. ...more

Akin Gump Strauss Hauer & Feld LLP

NYAG Suit Against Former CEO for Insider Trading Under Martin Act Signals Greater State Securities Enforcement Ahead

On January 15, 2026, the New York State Attorney General (NYAG) filed a civil suit against the former CEO of Emergent BioSolutions Inc. (Emergent), Robert G. Kramer, alleging that his sales of company shares pursuant to a...more

Foley Hoag LLP - White Collar Law &...

Securities Enforcement and Regulatory Developments from the SEC, CFTC, and PCAOB

This is the third in our 2026 Year in Preview series examining important trends in white collar law and investigations in the coming year. 2025 saw fundamental shifts in securities enforcement priorities in the first year of...more

Troutman Pepper Locke

Update: US Insider Reporting Requirements Coming for Directors and Officers of Foreign Private Issuers

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Effective March 18, 2026, officers and directors of foreign private issuers that have securities listed on a U.S. securities exchange or registered with the Securities and Exchange Commission (SEC) (for purposes of this...more

Carlton Fields

A New “Sheriff of Wall Street”: New York Attorney General Revives Martin Act in Pursuit of Insider Trading Case Against Former...

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In the early 2000s, then–New York Attorney General Eliot Spitzer earned the moniker “Sheriff of Wall Street” through an aggressive enforcement campaign targeting some of the financial industry’s most powerful institutions. ...more

White & Case LLP

SEC FY 2025 Review: A transformative year in SEC enforcement

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When Paul Atkins assumed the role of Chairman of the US Securities and Exchange Commission (SEC) last April, we anticipated a significant transformation in the Commission’s enforcement strategy, as a leaner, more streamlined...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

Akin Gump Strauss Hauer & Feld LLP

SEC Enforcement Action Targets Insider Trading in the Pharmaceutical Industry

On December 22, 2025, the U.S. Securities and Exchange Commission (SEC) filed a complaint against several defendants for their roles in market manipulation schemes involving two pharmaceutical companies, Olema...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

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

Carlton Fields

Officers and Directors of Foreign Private Issuers Will Be Subject to Section 16(a) Reporting Requirements

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Buried in the defense spending bill adopted in December 2025 is a provision amending Section 16(a) to extend insider reporting obligations to certain insiders of foreign private issuers (FPIs). The provision, dubbed the...more

Sheppard Mullin Richter & Hampton LLP

Section 16(a) Reporting Obligations to Apply to Officers and Directors of Foreign Private Issuers Starting March 18, 2026

On December 18, 2025, the Holding Foreign Insiders Accountable Act (“HFIAA”) was enacted as part of the FY 2026 National Defense Authorization Act. This new law amends Section 16(a) of the Securities Exchange Act of 1934, as...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

Troutman Pepper Locke

US Insider Reporting Requirements Coming for Directors and Officers of Foreign Private Issuers

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Officers and directors of certain foreign private issuers[1] that have securities listed on a U.S. securities exchange or registered with the Securities and Exchange Commission (SEC) (for purposes of this alert, FPIs) will...more

Seward & Kissel LLP

The End of the Exemption from Filing Statements of Beneficial Share Ownership for Officers and Directors of Foreign Private...

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On December 18, 2025, President Trump signed into law the National Defense Authorization Act for Fiscal Year 2026, which contained a provision eliminating certain reporting exemptions for SEC-registered companies qualifying...more

Ballard Spahr LLP

New Law Extends Insider Reporting Requirements to Foreign Private Issuers

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President Trump signed a law late last week that amends Section 16(a)(1) of the Securities Exchange Act of 1934, as amended, to subject foreign private issuers (FPIs) to the reporting requirements for directors, officers, and...more

Morrison & Foerster LLP

Section 16 Reporting Required for Foreign Private Issuers in 2026

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On December 18, 2025, President Trump signed into law the Holding Foreign Insiders Accountable Act (HFIAA), which eliminates a long-standing exemption that enabled foreign private issuers (FPIs) to avoid insider reporting...more

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