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Bounty Hunters: SEC Pays Record Amount to Whistleblower

On May 5, 2023, the Securities and Exchange Commission (“SEC”) issued an order (the “Order”)1 providing that it would pay a $279 million award to a whistleblower who assisted with the enforcement of an action by the SEC and...more

Non-GAAP Nonsense: SEC Charges DXC Technology with Misleading Non-GAAP Reporting and Deficient Disclosure Controls

On March 14, 2023, the Securities and Exchange Commission (“SEC”) issued a cease-and-desist order (the “Order”)1 and charged DXC Technology Company (“DXC”), an IT company based in Virginia, with violations of Rule 100(b) of...more

Missing Gold: Misappropriation by SPAC CFO Underscores Importance of Internal Controls

On February 22, 2023, the Securities and Exchange Commission (“SEC”) issued a cease-and-desist order (the “Order”) charging African Gold Acquisition Corp. (“African Gold”) with multiple violations of the Securities Exchange...more

Insider Trading Update: Recent Developments And Compliance Risks

Two separate, recent lines of cases have continued to shape the circumstances under which insider trading prosecutions can be brought, and as a result, the insider trading compliance risks faced by companies. First, the...more

Fifth Circuit: “Everybody Knew” Evidence Insufficient For Willfulness

A recent Fifth Circuit decision, United States v. Nora,1 reversed a clerical employee’s convictions for conspiring to commit health care fraud, conspiring to pay or receive illegal health care kickbacks, and aiding and...more

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