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SEC Enforcement Heats up on Key Public Company Topics: Cyber Disclosure, Director Independence and Regulation FD

The U.S. Securities and Exchange Commission's ("SEC") Division of Enforcement has recently brought a spate of enforcement actions relating to key topics for public companies. These include enforcement actions related to...more

Time to Review Whistleblower Provisions: SEC Charges Seven Public Companies with Violation of Whistleblower Protection Rule

On September 9, 2024, the US Securities and Exchange Commission (“SEC”) announced settled charges against seven public companies for violation of the whistleblower protection rule in connection with employment, separation,...more

SEC Continues Focus on Off-Channel Communications

On August 14, the U.S. Securities and Exchange Commission (“SEC”) announced yet another wave of enforcement actions related to widespread “off-channel communications,” charging an additional 26 firms with failing to maintain...more

Supreme Court rules SEC use of in-house tribunals is unconstitutional in potentially far-reaching decision

On June 27, 2024, the Supreme Court ruled in SEC v. Jarkesy that when the Securities and Exchange Commission (SEC) seeks civil penalties from defendants for securities fraud, the Seventh Amendment requires it to bring the...more

SEC Warns Individual Actors of Potential Liability for AI-Related Security Risk Disclosure Failures

Over the past few months, the Securities and Exchange Commission (the "SEC") has issued several warnings to companies to ensure accurate disclosure of the role and risks of artificial intelligence ("AI") in their businesses....more

New Settlements Demonstrate the SEC’s Ongoing Efforts to Hold Companies Accountable for AI-Washing

In the past few months, we have published several alerts concerning the increase in regulatory attention to "AI washing," or making unfounded claims regarding artificial intelligence ("AI") capabilities.1 Senior officials at...more

SEC Enforcement Director Emphasizes Current Tools Exist for Combatting Inaccurate Environmental Disclosures

While there are news reports that the U.S. Securities and Exchange Commission ("SEC") is on the verge of issuing new climate related disclosure rules for public companies, the SEC's Director of the Division of Enforcement...more

How to Avoid Risk of SEC Whistleblower Rule Violations in Connection with Settlement Agreement Confidentiality Provisions

In March 2023, we published an alert concerning the U.S. Securities and Exchange Commission ("SEC") whistleblower protection rule and how to minimize the risk of violations in connection with employee-related documents.1 Last...more

SEC Lists Crypto and Information Security Among its 2024 Examination Priorities

On October 16, 2023, the US Securities and Exchange Commission ("SEC") Division of Examinations ("Examination Division") announced its 2024 Examination Priorities. Registrants should ensure that policies, procedures, and...more

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

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

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