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Holland & Knight LLP

SEC Expands Scope of Internal Accounting Controls in Cybersecurity Breach Settlement

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The SEC continues to expand its cybersecurity enforcement authority to include allegations that a company's failure to monitor its managed security service providers (MSSP) amounts to violations of federal securities laws....more

Morrison & Foerster LLP

Top 5 SEC Developments (November 2023)

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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 announcement of its Fiscal Year 2023 enforcement...more

BCLP

Is It Time to Take a Fresh Look at Disclosure Controls and Procedures for CEO/CFO Certifications?

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In New England Carpenters Guaranteed Annuity and Pension Funds v. DeCarlo (Aug. 2023), the Second Circuit held, among other things, that CEO/CFO certifications mandated by SOX Section 302 constitute non-actionable statements...more

Holland & Knight LLP

Risky Business: SEC Expands DCP Enforcement Using Company Risk Factors

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Outside of the small circle of federal securities law nerds (we proudly proclaim our membership), the phrase "disclosure controls and procedures" (DCP) rarely garners much attention. However, a recent settled order issued by...more

WilmerHale

SEC Insider Trading Enforcement Highlights from 2021

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The Securities and Exchange Commission’s (SEC or Commission) actions in 2021 demonstrate that insider trading remains a key enforcement priority. While the absolute number of insider trading enforcement actions brought by the...more

Cooley LLP

Blog: Commissioners Peirce and Roisman criticize “unduly broad view” of “internal accounting controls” in Andeavor

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In October, the SEC settled charges against Andeavor, an energy company formerly traded on the NYSE and now wholly owned by Marathon Petroleum, in connection with stock repurchases authorized by its board in 2015 and 2016. ...more

Epiq

SEC Remains Focused on Cybersecurity

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After a long silence since guidance was last issued a year ago, there’s now widespread expectation that the Securities and Exchange Commission will get much more specific this year about new cybersecurity disclosures for...more

Jones Day

Anti-Corruption Regulation Survey of 41 Countries 2017–2018

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Welcome to the 2017-2018 edition of the Jones Day Anti-Corruption Regulation Survey. In 2017 and 2018 to date, there has continued to be an increasing awareness among multinational companies of the significance of...more

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