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Employment Agreements in The SEC’s Cross-Hairs: What Employers Should Do Now

Over the past several months, the U.S. Securities and Exchange Commission (“SEC”) has concluded several aggressive enforcement actions related to supposed violations of Rule 21F-17 under the Securities Exchange Act of 1934,...more

Latest SEC Guidance on Rule 10b5-1 Amendments

As discussed in our December 15, 2022 post, significant amendments to Rule 10b5-1 plan requirements took effect earlier this year. With the Justice Department announcing its first criminal prosecution challenging a Rule...more

Criminal indictment of Executive Chairman and parallel civil charges show Feds' willingness to challenge Rule 10b5-1 trading plans

The Justice Department recently indicted the Executive Chairman of Ontrak, Inc. alleging that he failed the “clean hands” requirement because he had been aware of material nonpublic information relating to the potential loss...more

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