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Breach of Duty Compliance

Morrison & Foerster LLP

Top 5 SEC Enforcement Developments for April 2024

Each month, we publish a roundup of the most important SEC enforcement developments for busy in-house lawyers and compliance professionals. This month, we examine: •The SEC’s first “Shadow Trading” trial; •SCOTUS’s...more

Kohrman Jackson & Krantz LLP

Protecting Your Company’s Confidential Information: Takeaways from Meta’s Lawsuit Against Its Former Employee

Meta Platforms Inc., the parent company of Facebook, Instagram, and other products, recently filed a lawsuit in a California state court against a former vice president for allegedly taking confidential information from Meta...more

Bass, Berry & Sims PLC

Welfare Plan Class Action Litigation Underscores Importance of Minding Your Fiduciary Duties

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As mentioned in our recent blog post, the recently filed class action lawsuit against Johnson & Johnson (Lewandowski v. Johnson & Johnson et. al., D.N.J., No. 1:24-cv-00671 (Feb. 5, 2024)) over alleged excessive prescription...more

BakerHostetler

AD-ttorneys@law - January 2024

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Extra, Extra, Read All About It! We have a major update! If you’re a subscriber to our blog, you have likely caught wind of our recent rebrand to ADventures in Law. Overflowing with a dynamic mix of weekly blogs, engaging...more

Dechert LLP

Caremark Claim Based on Business Risks Dismissed

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The Court of Chancery continues its consideration of whether a director or officer’s oversight duties, set forth in the seminal case of In re Caremark International Inc. Derivative Litigation and its progeny, apply to...more

ArentFox Schiff

Compliance Officers Beware: the SEC is Looking to Expand the Reach of Insider Trading

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On November 20, 2023, the Northern District of California denied summary judgment for the defendant in SEC v. Panuwat, an enforcement action being brought under a novel theory of insider trading law that is being referred to...more

Foley & Lardner LLP

Private Company Compliance: Investigations, Regulations, and Litigation

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We recently co-hosted an NACD “Private Company Compliance” webinar on the issues that directors of private companies should care about. In this episode, we focused on the increasing importance of supervising the...more

Davis Wright Tremaine LLP

Prudent Plan Governance Essential in Defense Against Fiduciary Breach

Although retirement plan excessive fee cases remain an ongoing concern for plan sponsors, the recent jury trial victory for Yale in Vellali, et. al. v. Yale University, et. al. provides hope for plans with strong, prudent...more

Proskauer - The Capital Commitment

Messaging Missteps: SEC’s Increasing Focus on Off-Channel Communications

The SEC’s Enforcement Division is conducting a sweep investigation of large investment advisers regarding their employees’ use of “off-channel” communications. The sweep, which has been widely reported in the press, focuses...more

A&O Shearman

FINRA Issues Regulatory Notice On The Scope Of Supervisor Liability For Chief Compliance Officers

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On March 17, 2022, FINRA issued a notice to member firms about Rule 3110 as it pertains to the potential liability of Chief Compliance Officers (CCOs) for failure to discharge designated supervisory responsibilities. ...more

The Volkov Law Group

The Delaware Court’s Decision Highlights Boeing’s Defective Corporate Culture and Board Governance Failures (Part II of IV)

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When considered in light of the Chancery Court’s decision, DOJ’s essential findings in its Boeing investigation are problematic at best.  The Chancery Court’s decision outlines how Boeing’s culture of safety deteriorated into...more

Proskauer - The Capital Commitment

The Portfolio Company Playbook: Chapter 4 – Navigating Direct Liability Risks to the Fund

As litigation claims against portfolio companies have increased, so have accompanying claims asserted directly against funds (and their sponsors). Plaintiffs’ reasoning for including funds as defendants is no mystery: funds...more

Proskauer - The Capital Commitment

Three Key Considerations for Fund Sponsors when Participating in Bankruptcy Proceedings

We anticipate a more assertive regulatory enforcement program under the Biden administration, particularly focused on fund managers’ conflicts of interest, advisers’ codes of ethics, and related policies and procedures...more

Proskauer - The Capital Commitment

SEC Cracks Down on Pension Fund Advisers’ Undisclosed Compensation and Conflicts

In August 2020, the SEC issued two orders against VALIC Financial Advisors Inc. (VFA) related to VFA’s management of 403(b) and 457(b) plans. These matters arise out of two of the SEC’s enforcement initiatives, the Teachers...more

Thomas Fox - Compliance Evangelist

Blue Bell: Failures of Role of the Board – Part 2: Caremark Duties

Over the past couple of blog posts, we have considered the guilty pleas by Blue Bell Creameries to charges that they distributed adulterated ice cream products and paid a criminal fine and forfeiture amount totaling $17.25...more

McDermott Will & Emery

Corporate Law & Goverance Update - January 2020

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Given evolving Delaware law, understanding the difference between “risk oversight” and “risk management” is an increasingly important board task. In the Marchand and Clovis decisions, the Delaware courts sent an important...more

Foley & Lardner LLP

Health Care Provider Director and Officer Liability: Important Takeaways from Clovis and Marchand

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Health care provider boards of directors have been put on notice—given these two recent Delaware court decisions - Clovis and Marchand—that courts may be willing to significantly extend a corporate board’s Caremark duty to...more

The Volkov Law Group

Delaware Court Increases Scrutiny of Corporate Board Oversight and Monitoring of Compliance Programs

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On October 1, 2019, in In re Clovis Oncology, Inc. Derivative Litigation, a Delaware Chancery Court denied a motion to dismiss the plaintiffs’ claims under the Caremark decision against individual directors for failing to...more

Foley & Lardner LLP

Board-Level Risk Oversight Deserves Renewed Attention

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Board oversight of significant company risk areas and legal compliance deserves renewed attention, as the Delaware Supreme Court recently ruled that monitoring practices that have previously been considered acceptable may...more

Jones Day

Delaware Chancery Court Addresses Directors’ Duty to Monitor Mission-Critical Regulatory Compliance

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The Situation: Directors of a biopharmaceutical company face potential liability where they knew—or should have known—that the company was not complying with regulations governing a matter of critical importance to the...more

Faegre Drinker Biddle & Reath LLP

A Director’s Mission: Understanding, Monitoring and Accurately Reporting Mission Critical Operations

On October 1, 2019, the Court of Chancery rendered an opinion in In re Clovis Oncology, Inc. Derivative Litigation, denying a motion to dismiss a Caremark claim for breach of fiduciary duty and reinforcing a director’s duty...more

The Volkov Law Group

Board Members Should Take Note — Delaware Supreme Court Issues Important Decision on Caremark Compliance Standard

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I have long predicted that corporate board members are in for a rude awakening. Corporate boards have to improve their ability and knowledge surrounding supervision and monitoring of a company’s ethics and compliance...more

Dechert LLP

Delaware Supreme Court Reverses Dismissal of Caremark Claim, Finding Lack of Board-Level Oversight and Director Independence

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In Marchand v. Barnhill et al. (“Blue Bell”),1 the Delaware Supreme Court on June 19 unanimously reversed the dismissal of a shareholder derivative lawsuit against the members of the board of directors and two officers of...more

McDermott Will & Emery

Corporate Law & Governance Update - May 2018

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Major Workforce Culture Controversy - A recent, highly-publicized controversy provides a near-worst case scenario of how workforce culture issues can damage corporate reputations and raise questions about board oversight. ...more

Foley & Lardner LLP

A Compilation of Enforcement and Non-Enforcement Actions

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Non-Enforcement - SEC Decides Against Mounting an Appeal in Koch Ruling - The July 2015 ruling by the D.C. Circuit Court in Koch v. SEC will apparently not be challenged by the SEC. The Court ruled in that...more

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