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Due Process Enforcement Actions

Foley & Lardner LLP

U.S. Supreme Court Rules SEC Must Try Securities Fraud Cases in Federal Jury Trials Rather than In-House Courts

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On June 27, 2024, the U.S. Supreme Court ruled that when the SEC seeks civil penalties against a defendant for securities fraud, the Seventh Amendment entitles the defendant to a jury trial. In a 6–3 decision, Chief Justice...more

Husch Blackwell LLP

False Claims Act Insights - Railroaded! How to Approach the Twin Tracks of Parallel Proceedings

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Host Jonathan Porter is joined by Troy Clark, Director and Corporate Counsel with Wellstar Health System, to discuss the peculiarities and difficulties of tackling parallel proceedings, that is, investigations and/or...more

Venable LLP

FTC Constitutional Challenge Update: Fifth Circuit Delivers Illumina a Stocking Full of Coal

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Last week, the Fifth Circuit handed down an across-the-board rejection of four constitutional challenges raised by gene sequencing company Illumina in defending against the Federal Trade Commission’s merger challenge. Bah!...more

Ballard Spahr LLP

SDNY Court Finds Broad Fed Powers Over Master Accounts in Puerto Rican Bank Case Involving AML Concerns

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The United States District Court for the Southern District of New York (the “Court”) has issued a detailed and complicated Order in the case Banco San Juan Internacional, Inc. v. Fed. Reserve Bank of New York, denying a...more

Jones Day

Ripple and Terraform Labs: Two New York District Courts Address the Status of Certain Crypto Assets as Securities

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In Short - The Situation: Recently, two judges in Southern District of New York were required to apply the Howey test in separate cases to decide whether sales of certain crypto assets were investment contracts, and thus...more

Latham & Watkins LLP

SEC v. Ripple: A Tale of Two Token Transaction Types

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A bifurcated decision in a highly anticipated digital assets enforcement action may not provide the clarity that market participants want or need. On July 13, 2023, Judge Analisa Torres of the US District Court for the...more

Holland & Knight LLP

Will Howey Progeny Stifle Ripple's Fair Notice Affirmative Defense?

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In the latest chapter of the high-profile SEC v. Ripple Labs, Inc., et. al. litigation, the SEC revisits its prior attempt to strike down the defendants' due process affirmative defense. Nearly a year after the SEC failed to...more

Nutter McClennen & Fish LLP

Nutter Securities Enforcement Update: May 1, 2022

The Nutter Securities Enforcement Update is a periodic summary of noteworthy recent securities enforcement activity, settlements, decisions, and charges. ...more

McDermott Will & Emery

Views and Lessons from the Trenches of the First Criminal No-Poach Trial

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In a landmark case of first impression, the US Department of Justice’s (DOJ) Antitrust Division (Division) indicted and brought to trial a federal criminal prosecution alleging agreements between DaVita, Inc., its former CEO...more

Patterson Belknap Webb & Tyler LLP

SEC Shadow Trading Case Breaks Ground – But There Remains a Trail to Blaze

A California Court recently allowed the Securities and Exchange Commission (the “SEC” or “Commission”) to proceed with its first insider trading prosecution based on a theory of “shadow trading.” On January 14, 2022, Judge...more

Kramer Levin Naftalis & Frankel LLP

Second Circuit Declines to Strike Down No-Deny Provision of Executive’s SEC Consent Agreement

On Sept. 27, 2021, the U.S. Court of Appeals for the Second Circuit rejected the most recent legal challenge to the Securities and Exchange Commission’s (SEC) practice of using “no-deny” consent agreements to resolve civil...more

Proskauer - Minding Your Business

One to Watch: Constitutional Challenges to NYC’s Price Gouging Rule

On March 18, 2021, retailer Union Square Supply, Inc. filed a civil rights class action lawsuit in the Southern District of New York challenging New York City’s price gouging enforcement practices. The complaint alleges that...more

White & Case LLP

Patriot Act Subpoenas: Reinvigorated and Reaching Across Borders

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The override of former President Trump's veto of the National Defense Authorization Act of 2021 resulted in the enactment of broad amendments to the US anti-money laundering regime. Among the amendments are provisions to...more

K&L Gates LLP

Voluntary Disclosure: Newsflash – October 2020

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In this episode, we examine how two criminal defendants are aiming to leverage parallel FCPA investigations by the SEC and the DOJ to build their defense. We’ll also offer our thoughts on the SEC’s new (and improved?)...more

McGlinchey Stafford

Florida Real Property & Business Litigation Report, Volume 13, Issue 26

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Liu v. Securities And Exchange Commission, Case No. 18–1501 (2020). Equitable relief, including disgorgement, is permissible under the Securities Act of 1933, 15 U. S. C. §77a et seq., so long as it does not exceed a...more

Holland & Knight LLP

ANI suspende términos en las actuaciones administrativas y contractuales en Colombia por COVID-19

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Debido a la situación generada por el COVID-19, la Agencia Nacional de Infraestructura (ANI) de Colombia emitió la Resolución 471 de 2020, que adopta medidas transitorias para garantizar la seguridad de la salud de los...more

Akin Gump Strauss Hauer & Feld LLP

Red Notice Newsletter - January 2020

IN THIS ISSUE • Anticorruption Developments • Export Control Sanctions and Customs Enforcement • Export Control and Sanctions Developments • Global Investigations Resources • Writing and Speaking Engagements ...more

The Volkov Law Group

OFAC Loses Exxon Sanctions Enforcement Case

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In an interesting end of year decision, issued on December 31, 2019, a District Court in Dallas issued a rejected OFAC’s enforcement action against Exxon Corporation imposing a $2 million penalty for violation of the Russia...more

Bradley Arant Boult Cummings LLP

“Two Wrongs Don’t Make a Right, But a Few More Can Make a Unicorn”

Class actions typically involve a proposed class of plaintiffs seeking recovery from the same defendant on similar grounds. But that is not the only animal in the class action corral. Rule 23 makes this clear in its very...more

UB Greensfelder LLP

FINRA Proposes To Dispense With Due Process, All Because It’s Failed To Do Its Job Of Policing The Markets

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Reading Reg Notice 19-17 makes me think of the legal arguments that I’ve recently read regarding whether a president can be found guilty of obstructing justice if the actions in question were taken out in the open, for...more

UB Greensfelder LLP

The Seventh Amendment Right to Jury for Violations of the Commodity Exchange Act – Part II

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This is the second part of a two-part article discussing a defendant’s Seventh Amendment right to jury in an enforcement action by the Commodity Futures Trading Commission under the Commodity Exchange Act for civil monetary...more

UB Greensfelder LLP

The Seventh Amendment Right to Jury for Violations of the Commodity Exchange Act – Part I

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This is the first of a two-part article discussing a defendant’s Seventh Amendment right to jury in an enforcement action by the Commodity Futures Trading Commission under the Commodity Exchange Act for civil monetary...more

Dechert LLP

Appellate Court Directs FTC to Be More Specific in its Data-Security Orders

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In a closely watched data-security case, the U.S. Court of Appeals for the Eleventh Circuit vacated as unenforceable a cease and desist order issued by the U.S. Federal Trade Commission (FTC) against LabMD, Inc. According to...more

Fenwick & West LLP

SEC Enforcement Trends: Highlights from Securities Enforcement Forum West 2018

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The Securities Enforcement Forum West 2018 brought together current and former senior U.S. Securities and Exchange Commission and U.S. Department of Justice officials, securities enforcement and white-collar attorneys,...more

Dechert LLP

Tenth Circuit Court of Appeals Finds SEC’s Process for Designating Administrative Law Judges to be Defective, Causing Split with...

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The U.S. Court of Appeals for the Tenth Circuit on December 27, 2016, in Bandimere v. SEC, found the Administrative Law Judges (ALJs) used by the U.S. Securities and Exchange Commission (SEC) to hear its administrative...more

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