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SEC Enforcement Broadens Its Crypto Focus

On May 6, 2022, the U.S. Securities and Exchange Commission announced that it settled charges against NVIDIA Corporation alleging that the company’s disclosures regarding the impacts of increased use of its gaming products by...more

SEC Proposes Changes To Whistleblower Program Rules

On February 10, the U.S. Securities and Exchange Commission proposed two amendments to the rules governing its whistleblower program, Exchange Act Rules 21F-3 and 6. “These amendments, if adopted, would help ensure that...more

2021 Year in Review: FCPA

A. Basic Overview of Statute - The Foreign Corrupt Practices Act of 1977, as amended, 15 U.S.C. §§ 78dd-1, et seq. (FCPA), makes it unlawful for U.S. persons and entities and others who act within the jurisdiction of the...more

United Food’s “New” Delaware Demand Futility Test: The More Things Change, the More They Stay the Same

On September 23, 2021, in United Food and Commercial Workers Union v. Zuckerberg et al., the Delaware Supreme Court restated and refined the demand futility test for bringing shareholder derivative claims when it affirmed the...more

Get Your Board On Board with Limiting SPAC-Related Litigation Risk

Although Special Purpose Acquisition Companies (SPACs) have been around for decades, only recently have they experienced an incredible surge in popularity and, inevitably, attention from regulators and plaintiffs’ law firms....more

When Perquisites Stop Being Fun And Create Serious Liability Risks To An Issuer

Last week, the U.S. Securities and Exchange Commission (“SEC”) brought enforcement actions against a company and its former CEO for failure to adequately disclose certain compensation and related party transactions. The move...more

ISS 2021 Policy Updates On Federal Forum And Exclusive State Law Forum Provisions, Board Diversity And Other Matters

Institutional Shareholder Services (“ISS”) published its proxy voting guidelines updates for 2021 (“Policy Updates”) on November 12, 2020. The changes that are likely to be of most interest to companies include new and...more

When Do M+A Discussions Constitute MNPI? Recent SEC Guidance May Shed Some Light

Last month, the SEC announced that a public company had agreed to pay a $20 million penalty to resolve charges related to its repurchase of stock while supposedly in possession of material, non-public information (“MNPI”)...more

Talking The Talk Versus Walking The Walk: Shareholder Suits Aim To Push Board Diversity And Punish Companies Supposedly Failing To...

A lot of attention has been paid to board diversity – or lack thereof – in recent months. California enacted AB-979, which expanded upon California’s earlier gender diversity law and requires boards to make strides in other...more

Minimizing U.S. Fitness Facility Operators’ Potential COVID-Related Liability

Now that indoor fitness centers around the country are reopening, fitness facility operators are concerned about potential liability for COVID-related illnesses. This is because even the most conscientious business operators...more

COVID-19 Litigation And Government Investigations In the U.S.: What We Are Seeing Now, And What The Future Holds

The emergence of COVID-19 has led to increased litigation and government activity across all industries, and this trend is only likely to accelerate. To assist you in better understanding your risk, we have examined matters...more

U.S. Sanctions Compliance During COVID-19: Pandemic-Related Guidance from the Office of Foreign Assets Control

The Office of Foreign Assets Control of the U.S. Department of the Treasury (“OFAC”) released brief policy guidance on April 20, 2020, addressing the COVID-19 pandemic’s impact on the capability of the global business...more

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