News & Analysis as of

Administrative Proceedings Enforcement Actions

Mintz

SEC Imposes $17.5 Million Fine Against Investment Adviser for Greenwashing

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3 On November 8, the SEC and an investment advisor entered into a settlement to resolve an administrative proceeding featuring allegations of greenwashing. Specifically, the investment advisor was alleged to have made...more

Cozen O'Connor

Navigating the Future: Key Takeaways & Insights from the 2024 Securities Enforcement Forum Central

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One of the concerns following the Supreme Court’s ruling in SEC v. Jarkesy was that other agencies may face similar collateral attacks to its administrative proceedings. While the full impact of Jarkesy remains an open...more

Ballard Spahr LLP

Citing Jarkesy, Asbury Automotive Group files suit challenging FTC administrative proceeding

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One of the country’s largest automotive retailers filed suit against the Federal Trade Commission (“FTC”) on October 4, arguing that the Supreme Court’s recent landmark decision in Securities and Exchange Commission v....more

Goodwin

FTC Escalates Battle Against PBMs With Complaint on Insulin Pricing

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FTC’s challenge is the culmination of years of investigation, but choice of venue and theories of harm reveal potential weaknesses....more

Cranfill Sumner LLP

After Jarkesy, What Is Next for In-House Enforcement Proceedings?

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Much virtual ink has been spilled in the weeks and months since the Supreme Court issued its opinion in Securities and Exchange Commission v. Jarkesy—much attesting to that the decision was the death knell for in-house...more

Orrick, Herrington & Sutcliffe LLP

Supreme Court Curtails Use of Administrative Courts in SEC Enforcement Proceedings: What it Means for Other Agencies and What...

The U.S. Supreme Court has ruled that defendants in securities fraud cases brought by the SEC are entitled by the Seventh Amendment to have the SEC’s claims for civil money penalties decided by a jury and not in an...more

SEC Compliance Consultants, Inc. (SEC³)

Regulatory Roundup for July 2024

SEC Loses in ALJ Case, DOL’s Latest Fiduciary Rule Put on Hold, and SEC Reconsiders AI and Custody Rule Proposals - Welcome to our July Regulatory Roundup, where we provide a quick look at the latest regulatory developments....more

Stoel Rives - Environmental Law Blog

SEC v. Jarkesy: In-House Adjudicators are Out and the Jury is In

Why do environmental professionals need to know about a recent securities case? Read on for details. In response to the Wall Street Crash of 1929, Congress passed the Securities Act of 1933, the Securities Exchange Act of...more

Husch Blackwell LLP

The Justice Insiders Podcast: Jarkesy’s Implications for the Administrative State

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Host Gregg N. Sofer welcomes back to the podcast Richard Epstein, Laurence A. Tisch Professor of Law at New York University Law School, and Steve Renau, Husch Blackwell’s Head of Thought Leadership, to discuss the U.S....more

Steptoe & Johnson PLLC

Two U.S. Supreme Court Decisions Will Affect the Securities Industry

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The Supreme Court of the United States (SCOTUS) recently issued two opinions that are likely to have a longer-term effect on the way securities industry matters are handled. Juries, not the Securities Exchange Commission...more

Lowenstein Sandler LLP

Supreme Court: SEC Cannot Force Defendants in Civil-Penalty, Antifraud Enforcement Actions To Litigate Before the Commission...

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The U.S. Supreme Court recently decided SEC v. Jarkesy. That decision held that individuals subject to U.S. Securities and Exchange Commission (SEC or Commission) enforcement actions in which the SEC seeks civil penalties for...more

Kramer Levin Naftalis & Frankel LLP

Supreme Court Limits SEC’s In-House Adjudicative Powers

On June 27, 2024, in Securities and Exchange Commission v. Jarkesy, the Supreme Court held that the Securities and Exchange Commission’s (SEC or the Commission) administrative process for adjudicating fraud-based enforcement...more

Foley Hoag LLP - White Collar Law &...

Supreme Court Significantly Limits the SEC’s Enforcement Power by Prohibiting Administrative Proceedings for Securities Fraud

On June 27, 2024, the U.S. Supreme Court issued its decision in Securities and Exchange Commission v. Jarkesy. In a 6-3 decision, the Court ruled that securities fraud claims seeking civil penalties must be decided by a jury...more

Patterson Belknap Webb & Tyler LLP

Supreme Court Decision in SEC v. Jarkesy Limits the SEC’s Ability to Seek Civil Penalties

On June 26, 2024, the Supreme Court issued a decision in SEC v. Jarkesy, holding that “[w]hen the SEC seeks civil penalties against a defendant for securities fraud, the Seventh Amendment entitles the defendant to a jury...more

Wiley Rein LLP

Supreme Court Holds That Federal Agencies May Seek Punitive Money Penalties Only Before A Jury

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Last week the U.S. Supreme Court held in SEC v. Jarkesy that a defendant in a securities fraud suit has the right to be tried by a jury in an Article III court, rather than before an agency’s own tribunal. The Court’s...more

The Volkov Law Group

BIS Announces Settlement Agreement with Indiana University Over Export Control Violations

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On June 24, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) announced the settlement of an administrative enforcement action involving Indiana University of Bloomington (“Indiana University”)...more

Womble Bond Dickinson

SEC v. Jarkesy: How Impactful Is It Really on the SEC’s Enforcement Program?

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In SEC v. Jarkesy, the Supreme Court held that the Seventh Amendment requires the U.S. Securities and Exchange Commission (“SEC” or “the Commission”) to litigate in federal district court when seeking civil monetary penalties...more

Davis Wright Tremaine LLP

SEC v. Jarkesy: Supreme Court Delivers Significant Blow to SEC Intra-Agency Enforcement

SCOTUS limits agency use of ALJs in civil penalty proceedings - On June 27, 2024, in a 6-3 decision, the Supreme Court held in SEC v. Jarkesy that the Securities and Exchange Commission ("SEC" or the "Commission") could...more

Baker Donelson

U.S. Supreme Court Declares SEC's Action for Civil Money Penalties Unconstitutional, Upending Administrative Enforcement Powers

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On June 27, 2024, the U.S. Supreme Court affirmed a Fifth Circuit decision that called into question the future of certain in-house administrative enforcement actions, which we reviewed here. Specifically, in Securities and...more

Skadden, Arps, Slate, Meagher & Flom LLP

Supreme Court Holding That SEC Actions Seeking Civil Penalties for Securities Fraud Must Be Heard by a Jury Calls Into Question...

In Securities and Exchange Commission v. Jarkesy, the U.S. Supreme Court held that “the Seventh Amendment entitles a defendant to a jury trial when the [Securities and Exchange Commission] seeks civil penalties against him...more

Venable LLP

Jarkesy: SEC Change-Up - The Supreme Court Curbs the Use of Administrative Courts for Litigated Fraud Claims and Civil Penalties

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In a landmark decision issued last week, SEC v. Jarkesy, the Supreme Court held that the Seventh Amendment guarantees a defendant a jury trial when the SEC seeks civil penalties against the defendant for committing securities...more

Cozen O'Connor

U.S. Supreme Court Declares Unconstitutional SEC’s Admin Courts Hearing of Fraud Cases When Seeking Civil Penalties

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On June 27, 2024, the U.S. Supreme Court in SEC v. Jarkesy struck a major blow to the U.S. Securities and Exchange Commission’s enforcement powers by declaring as unconstitutional the SEC’s use of its in-house administrative...more

Miller Canfield

U.S. Supreme Court Curtails Securities and Exchange Commission’s In-House Authority to Penalize Securities Fraud

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On June 28, 2024, the Supreme Court issued a significant decision that could have wide-ranging consequences for administrative agency enforcement actions. In Securities and Exchange Commission v. Jarkesy, the Court held that...more

BakerHostetler

Supreme Court Limits SEC Administrative Actions, Upholds Defendants’ Right to a Jury

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On Thursday, June 27, the Supreme Court, in a 6-3 decision, held that the Seventh Amendment entitles a defendant to a jury trial in instances where the SEC seeks civil penalties against that defendant for alleged securities...more

Dechert LLP

Supreme Court Curtails SEC In-House Judges on Litigated Civil Penalties

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In SEC v. Jarkesy, the Supreme Court held that the Seventh Amendment entitles a defendant to a jury trial when the SEC seeks civil penalties for securities fraud. The decision limits the SEC’s authority to seek civil...more

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