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US Congress Affirms and Expands SEC’s Disgorgement Authority in Annual Defense Spending Bill

The legislation - passed via the first congressional override of the Trump presidency - extends the SEC’s ability to obtain disgorgement for violations of federal securities laws. Key Points: ..As amended, the...more

US Supreme Court Upholds SEC’s Authority to Seek Disgorgement

Questions about the scope of the SEC’s disgorgement authority remain open, including in administrative proceedings. Key Points: ..Since the April 2017 decision in Kokesh v. SEC, the statutory authority of the Securities...more

Second Circuit Reinforces FCPA’s Jurisdictional Limits

Ruling holds that the government cannot use conspiracy and accomplice liability theories to reach foreign nationals that lack US ties. Key Points: ..Non-resident foreign nationals who are not otherwise subject to direct...more

Supreme Court: SEC ALJs Are Officers Subject to Constitution’s Appointments Clause

Respondents in pending or future proceedings should carefully assess their options until several key legal questions are resolved. The United States Supreme Court recently issued its ruling in Lucia v. Securities and...more

SEC Enforcement Division Issues Guidance on Venue Selection

Respondents in SEC enforcement actions increasingly will litigate a wide array of matters in administrative proceedings, rather than having their day in federal district court. In the wake of significant public...more

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