News & Analysis as of

SEC v Jarkesy

Perkins Coie

Fifth Circuit Rules FCC Enforcement Action Unconstitutional

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Key Takeaways - - The U.S. Court of Appeals for the Fifth Circuit vacated a $57 million fine levied by the Federal Communications Commission (FCC) against AT&T. - The court ruled the FCC's in-house enforcement proceedings...more

Venable LLP

Fifth Circuit Decision Vacating FCC Fine Against AT&T Makes It More Difficult for Federal Agencies to Impose Monetary Penalties...

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The Fifth Circuit on April 17 vacated a $57 million FCC forfeiture against AT&T, ruling the agency violated the company’s Seventh Amendment right to a jury trial under the Supreme Court’s 2024 decision in SEC v. Jarkesy. ...more

Fox Rothschild LLP

Another Civil Penalty Falls under Jarkesy – What’s Next?

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On April 17th, the Fifth Circuit Court of Appeals held that an FCC penalty violates the Seventh Amendment based on the Supreme Court’s landmark ruling in SEC v. Jarkesy. The Seventh Amendment provides for the...more

Troutman Pepper Locke

White House Issues Memorandum Directing Federal Agencies to Repeal Regulations Deemed to be Unlawful Pursuant to Recent U.S....

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On April 9, the White House issued a memorandum directing federal executive departments and agencies to repeal regulations deemed unlawful pursuant to certain U.S. Supreme Court decisions. This directive aims to address...more

Perkins Coie

Leveling the Playing Field? Developing Discovery Strategies in CFTC Civil Enforcement Actions

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The Commodity Futures Trading Commission’s Division of Enforcement wields immense power in civil enforcement actions. It often seeks financial sanctions, including hefty financial penalties, and injunctive relief that can...more

Haynsworth Sinkler Boyd, P.A.

What Employers Need to Know About Shifting Caselaw and Legislation

As employers navigate the complexities of a new political era and evolving regulatory framework, staying ahead of these changes isn't just advisable — it's essential. Several executive actions have already influenced...more

Cornerstone Research

SEC Accounting and Auditing Enforcement Activity Plummeted in Final Year of Gensler Administration

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The U.S. Securities and Exchange Commission (SEC) drastically reduced its accounting and auditing enforcement activity in fiscal year 2024, the final year of Gary Gensler’s administration, ending two consecutive years of...more

Cooley LLP

Are meme coins securities? Corp Fin says no

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Last week, Corp Fin issued a new statement providing its views on whether “meme coins” were securities or, if offered and sold, involved securities transactions. Meme coins are more like collectibles, the staff explained,...more

Skadden, Arps, Slate, Meagher & Flom LLP

Inside the Courts – An Update From Skadden Securities Litigators - February 2025

Key Points - - In 2024, securities litigation remained consistent with historical averages, with a slight increase in core filings and cases related to COVID-19 and artificial intelligence. - The U.S. Supreme Court had an...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

New Challenges Loom for OSHA and OSHRC Amid Quorum Issues, Potential ALJ Removals, and Recent Supreme Court Jurisprudence

“The Times They Are a-Changin’” isn’t just a Bob Dylan song title—it is also a fairly accurate description of what has been happening in the arena of the Occupational Safety and Health Administration (OSHA) and the...more

Cornerstone Research

PCAOB Enforcement Activity in 2024 Reached Highest Level Since 2017 as Monetary Penalties Hit New Record for the Third Consecutive...

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The Public Company Accounting Oversight Board (PCAOB) continued to expand its enforcement in the final year of the Biden administration, reaching the highest level of enforcement actions since 2017, according to a new report...more

Orrick, Herrington & Sutcliffe LLP

DOJ determines administrative law judges are unconstitutional

On February 20, Acting Solicitor General Sarah M. Harris wrote to Sen. Charles Grassley (R-IA), President pro tempore of the Senate, and Rep. Mike Johnson (R-LA), Speaker of the House, to disclose that, pursuant to 28 U.S.C....more

Carlton Fields

DOJ Withdraws Defense of SEC ALJs' Constitutionality as Trump Issues Executive Order on Agency Accountability

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On February 18, 2025, President Trump issued executive order 14215, titled “Ensuring Accountability for All Agencies,” with the stated purpose of making federal agencies, including independent regulatory ones like the...more

Foley Hoag LLP - White Collar Law &...

SEC Expected to Shift Priorities and Adopt a More Business-Friendly Approach in 2025

This is the fourth in our 2025 Year in Preview series examining important trends in white collar law and investigations in the coming year. We will be posting further installments in the series throughout the next several...more

Carlton Fields

Jarkesy May Reshape SEC Enforcement Against Professionals

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For decades, the SEC has relied on its in-house administrative proceedings to enforce alleged violations under the federal securities laws, including under its own rules of practice....more

Bradley Arant Boult Cummings LLP

Kansas Bank's Suit Could Upend FDIC Enforcement Authority

On Nov. 19, 2024, the Federal Deposit Insurance Corp. issued a notice of assessment finding that between December 2018 and August 2020, CBW Bank — a single-branch bank in Weir, Kansas — failed to maintain an adequate...more

A&O Shearman

Energy Company Settles Long-Running Dispute With FERC After Jarkesy Decision Undercuts FERC’s Enforcement Authority

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On January 8, 2025, the Federal Energy Regulatory Commission approved a stipulation and consent agreement between its Office of Enforcement and an energy company (the “Company”) to resolve a dispute pending since 2016...more

Mintz - Health Care Viewpoints

EnforceMintz —Could the Supreme Court’s Decision in Jarkesy Mean the End to HHS Civil Monetary Penalty Authorities as We Know...

Last June, the Supreme Court issued its decision in Securities and Exchange Commission v. Jarkesy, which holds that the Seventh Amendment entitles a defendant to a jury trial when the Securities and Exchange Commission (SEC)...more

Vinson & Elkins LLP

FERC Settles Decade-Old Enforcement Allegations

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In 2016, a new play called Hamilton was dominating Broadway, Pokémon Go was all the rage, and the Summer Olympics were held in Rio. Also that year, the Federal Energy Regulatory Commission (“Commission” or “FERC”) issued an...more

Ward and Smith, P.A.

Upping the Ante: New Rules and Regulations in Play for In-House Counsel

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Four Ward and Smith team members delivered concise, actionable insights on projected governmental and policy changes resulting from the recent elections, the Corporate Transparency Act, the implications of the Chevron...more

Fisher Phillips

Top 2025 Predictions for Workplace Safety

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Our Workplace Safety thought leaders have pulled together their top predictions for the new year so that employers can get a running start to 2025....more

Womble Bond Dickinson

Hidden in the NDAA: The Expanded Reach of the Program Fraud Civil Remedies Act

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Federal government contractors and many others have been closely watching the drafting, introduction, consideration, debate, amendment, and passage of the annual National Defense Authorization Act (“NDAA”)....more

Holland & Knight LLP

Buckle Your Seatbelt, It's Going to Be a Bumpy Ride … or Is It?

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Readers, thank you for journeying with us through all nine (and this, our 10th and final!) installments of Season's Readings. In this final piece, we turn from the past and look ahead to what may be in store from the SEC's...more

Brooks Pierce

Counting Down to the New Year: Ten “Need-to-Know” Labor and Employment Developments of 2024

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2024 was yet another active year in the labor and employment landscape. While 2025 and the new administration could bring any number of changes to workplace laws and enforcement, the timing and extent of such changes is...more

White & Case LLP

SEC Enforcement Year-End Overview

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2024 marks the final year of Gary Gensler's term as Chair of the U.S. Securities and Exchange Commission ("SEC"). The Gensler SEC has been aggressive on both the enforcement and rulemaking fronts. In response, the financial...more

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