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SEC Enforcement Broadens Its Crypto Focus

On May 6, 2022, the U.S. Securities and Exchange Commission announced that it settled charges against NVIDIA Corporation alleging that the company’s disclosures regarding the impacts of increased use of its gaming products by...more

SEC Proposes Changes To Whistleblower Program Rules

On February 10, the U.S. Securities and Exchange Commission proposed two amendments to the rules governing its whistleblower program, Exchange Act Rules 21F-3 and 6. “These amendments, if adopted, would help ensure that...more

2021 Year in Review: FCPA

A. Basic Overview of Statute - The Foreign Corrupt Practices Act of 1977, as amended, 15 U.S.C. §§ 78dd-1, et seq. (FCPA), makes it unlawful for U.S. persons and entities and others who act within the jurisdiction of the...more

When Perquisites Stop Being Fun And Create Serious Liability Risks To An Issuer

Last week, the U.S. Securities and Exchange Commission (“SEC”) brought enforcement actions against a company and its former CEO for failure to adequately disclose certain compensation and related party transactions. The move...more

When Do M+A Discussions Constitute MNPI? Recent SEC Guidance May Shed Some Light

Last month, the SEC announced that a public company had agreed to pay a $20 million penalty to resolve charges related to its repurchase of stock while supposedly in possession of material, non-public information (“MNPI”)...more

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