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The Currency and Foreign Transactions Reporting Act, also known as the “BSA,” enacted in 1970, established requirements for record-keeping and reporting by banks and other financial institutions. The BSA is designed to, among...more
The US Securities and Exchange Commission (SEC) recently released two new sources of guidance for the Marketing Rule. On February 26, the SEC Division of Investment Management released an FAQ clarifying how to include gross...more
On April 17, 2024, the Division of Examinations (the “Division”) of the Securities and Exchange Commission (the “SEC”) published a Risk Alert entitled: “Initial Observations Regarding Advisers Act Marketing Rule Compliance”...more
The Nutter Securities Enforcement Update is a periodic update of noteworthy recent securities enforcement activity, settlements, decisions, and charges. We provide brief summaries that highlight recent enforcement action...more
Corporate ethics and compliance officers have long argued that maintaining an ethical corporate culture is important to a business for all sorts of reasons. Now you might be able to offer one more: failing to maintain an...more
Greenwashing is under increased scrutiny at the Securities and Exchange Commission (SEC) and the Federal Trade Commission (FTC). Greenwashing is clearly damaging to consumers and investors as it imbues purchasing decisions...more
The Grinch is certainly a title that could be an allegory with disgraced Goldman Sachs Group Inc.’s former partner Tim Leissner about now. He was the lead Goldman Sachs banker who facilitated the firm’s work on bond offerings...more
Last week, the Commodity Futures Trading Commission publicized a cascade of settlements of enforcement actions alleging breaches of laws and rules related to supervision, spoofing, reporting, and misappropriation of...more
We are pleased to present our annual mid-year update on financial reporting and issuer disclosure enforcement activity for 2019. This White Paper primarily focuses on the U.S. Securities and Exchange Commission's enforcement...more
I. Advertising Rule Compliance Issues - On September 14, 2017, the staff of the SEC's Office of Compliance Inspections and Examinations (OCIE) issued a National Examination Program Risk Alert on the most frequent advertising...more
The U.S. Securities and Exchange Commission (SEC) continues to increase its enforcement efforts in the municipal bond market by focusing on the sufficiency and timeliness of disclosure in initial municipal securities...more
On May 27, 2014, an administrative law judge (ALJ) found ZPR Investment Management, Inc. (ZPRIM) and its former owner, Max Zavanelli, to have violated the Investment Advisers Act of 1940 for publishing misleading...more
On May 7, 2013 the Securities and Exchange Commission (SEC) and the City of Harrisburg, Pennsylvania concluded a years-long SEC investigation in a first-of-its kind settlement....more