On November 6, senior officials from the U.S. Securities and Exchange Commission (SEC) Division of Enforcement spoke at the Securities Enforcement Forum D.C. 2024, addressing anticipated leadership changes and enforcement priorities at the SEC. As summarized in our recent update, key takeaways from the forum are:
- The SEC may undergo significant changes, particularly regarding its enforcement priorities, with the incoming administration. The new chair will be the most important factor in how this takes shape.
- Registrants should review settlements in crypto enforcement to stay informed of the SEC’s evolving policies in this space.
- Keep in mind the SEC’s focus on AI when deploying AI and making AI-related disclosures.
- Regularly review disclosure controls and cybersecurity governance practices for compliance with SEC cybersecurity rules.
- Financial reporting fraud is highly likely to remain an enforcement priority for the SEC. Watch for increased focus on revenue recognition actions.
- Be aware of the importance of counsel’s credibility with the SEC. Clients should be receptive to counsel’s recommendations on strategy when submitting presentations or written materials to the SEC.
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