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SEC’s Focus on Off-Channel Communications Continues

On September 29, the US Securities and Exchange Commission ("SEC") brought its latest wave of enforcement actions related to "off-channel communications," charging 10 additional firms with failing to maintain employee...more

The SEC Continues to Prove it is the Most Powerful Influencer: How to Avoid Touting Charges

Recently, the US Securities and Exchange Commission ("SEC" or "the Commission") announced charges against eight celebrities, including Jake Paul, Soulja Boy, Lindsay Lohan, and Ne-Yo for unlawfully touting digital tokens...more

How to Avoid Risk of SEC Whistleblower Rule Violations in Connection with Employee-related Documents

On February 3, 2023, the US Securities and Exchange Commission ("SEC") announced that a public company agreed to pay $35 million to settle charges of, among other things, violations of the whistleblower protection rule.1...more

The SEC scored record penalties in fiscal year 2022

Many were anticipating an enforcement crackdown by the Securities and Exchange Commission (SEC) in the first full fiscal year under chair Gary Gensler and enforcement director Gurbir Grewal, and those expectations were...more

ESG is increasingly critical in US M&A, but greenwashing concerns persist

Buyers are scrutinizing everything from an acquisition target’s projected greenhouse gas (GHG) emissions to ways in which a deal may impact their own climate mitigation strategies. In this regard, reliable and verifiable...more

SEC: The watchdog bares its teeth

The Securities and Exchange Commission (SEC) has followed through on its much publicized intention of more aggressive enforcement. For instance, in June, the regulator brought an accounting fraud action that included a...more

SEC Proposes Mandatory Cybersecurity Disclosure Rules

On March 9, 2022, the Securities and Exchange Commission ("SEC") proposed rules that would require public companies to make prescribed cybersecurity disclosures. The proposed rules would "strengthen investors' ability to...more

How to Manage the Risks of SPAC Securities Fraud Actions in 2022

In March 2021, White & Case published a client alert entitled "How SPACs Can Manage the Risks of White Collar Scrutiny." The article discussed the surge in interest and publicity surrounding "SPACs" (Special Purpose...more

How Digital Asset Innovators Can Manage the Risks of White Collar Scrutiny in the US

Described as the "Wild West" by SEC Chairman Gary Gensler, the meteoric rise of digital assets like cryptocurrencies has disrupted the traditional financial ecosystem. The wave of enforcement actions brought by federal and...more

SEC enforcement ramps up

Dealmakers should be braced for a more aggressive stance under Chair Gary Gensler - The appointment of Gary Gensler to Chair of the Securities and Exchange Commission (SEC) signaled a break from the Trump administration,...more

Time to Revisit Insider Trading Policies: The SEC’s Expansion of Insider Trading Enforcement to “Shadow Trading” Survives Motion...

On January 14, 2022, in a closely watched decision, a federal judge in the Northern District of California denied a motion to dismiss a complaint brought by the US. Securities and Exchange Commission ("SEC") that presented a...more

SEC Focuses on Potential Misuse of Material Non-Public Information in Stock Trades: Proposed Amendments Regarding Rule 10b5-1...

To address what the SEC characterizes as "critical gaps" in its insider trading regime, on December 15, 2021, the Securities and Exchange Commission (the "SEC") voted unanimously to propose amendments to Rule 10b5-1 under the...more

SEC Extends the Misappropriation Theory of Insider Trading Beyond Targets of Acquisitions to Companies “Economically Linked” to...

In a landmark action, the US Securities and Exchange Commission ("SEC") filed a complaint alleging insider trading that expands the potential reach of insider trading law. On August 17, 2021, the SEC charged a former employee...more

SEC to take tougher line on enforcement

New Securities and Exchange Commission Chair Gary Gensler has put scrutiny of SPACs and private funds at the top of his agenda - President Biden's appointment of Gary Gensler as Chair of the US Securities and Exchange...more

SEC Statements Suggest Heightened Insider Trading Scrutiny Even if Using a Rule 10b5-1 Trading Plan

Recent warnings from the US Securities and Exchange Commission ("SEC") and the US Congress could translate into more aggressive scrutiny of trading plans adopted pursuant to Rule 10b5-1 of the Securities and Exchange Act of...more

More Aggressive White Collar Enforcement Expected Under the Biden Administration

The first 100 days of President Biden's administration, not least its appointments to key leadership positions, suggest that it will investigate and pursue white collar cases much more aggressively than the Trump...more

How SPACs Can Manage the Risks of White Collar Scrutiny

Notwithstanding the economic difficulties following the pandemic, 2020 saw a huge increase in initial public offerings ("IPOs") and merger activity relating to "SPACs" (Special Purpose Acquisition Companies). The number of...more

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