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Expect Focus - Volume II, May 2025

Builder of Investment Models Deviates From Blueprints Employee’s Rogue Remodeling Costs Builder Plenty - The SEC’s recent order instituting administrative and cease-and-desist proceedings (OIP) against registered...more

Builder of Investment Models Deviates From Blueprints - Employee’s Rogue Remodeling Costs Builder Plenty

The SEC’s recent order instituting administrative and cease-and-desist proceedings (OIP) against registered investment advisers Two Sigma Investments LP and Two Sigma Advisers LP illustrates significant risks for investment...more

Expect Focus - Volume I, January 2025

The Mysterious Boundary Beyond Which “Personal” Relationships Jeopardize a Director’s Independence - In a recent enforcement action, the SEC concluded that the relationship between James Craigie and an officer of Church &...more

Jarkesy May Reshape SEC Enforcement Against Professionals

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

DOJ Updates Evaluation of Corporate Compliance Programs Guidance: What Companies Need to Know

On September 23, 2024, the U.S. Department of Justice (DOJ) released updates to its Evaluation of Corporate Compliance Programs (ECCP) guidance — the framework prosecutors use to evaluate corporate compliance programs during...more

Can Government Use Criminal Fraud Statute to Get Around “Personal Benefit” Requirement for Insider Trading?

The government prosecutes insider trading against insiders who convey material nonpublic information (“tippers”) and outsiders who acquire material nonpublic information (“tippees”) through two avenues: civil proceedings...more

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