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Landmark SEC and DOJ Insider Trading Cases Signal Increased Scrutiny of Rule 10b5-1 Plans

Key Points - On March 1, 2023, the SEC and DOJ filed insider trading charges against a public company executive alleging he traded pursuant to 10b5-1 trading plans he adopted while he was in possession of material...more

A Fractured Framework: Regulatory Actions Against Mango Token Trader Highlight Complexities of Crypto Enforcement

Key Points - The recent indictment and multiple regulatory enforcement actions brought against a crypto trader alleged to have committed market manipulation highlight the ongoing fractured oversight of the crypto markets...more

DOJ Criminal Division Announces New Round of Revisions to Corporate Enforcement Policy

Key Points - On January 17, 2023, Assistant Attorney General Kenneth A. Polite, Jr. announced revisions to the DOJ Criminal Division’s corporate enforcement policy that offer new incentives to self-disclose corporate...more

Deputy AG Announces Significant Changes to DOJ Policies Regarding Corporate Investigations

Key Points - On September 15, 2022, Deputy AG Lisa O. Monaco released a Memorandum and provided remarks announcing several DOJ policy changes to prioritize and strengthen the Department’s prosecution of corporate crime....more

Increasing Government Enforcement in Insider Trading of Commodities

Key Points - The DOJ and CFTC have filed insider trading charges against a Houston-based energy trader for allegedly disclosing confidential information to a third party who then used the information to trade profitably....more

Department of Justice’s 2020 Update Moves the Needle on Guidance for Evaluation of Corporate Compliance Programs

- DOJ’s update offers additional insights into its approach to evaluating corporate compliance programs. - The update places emphasis on compliance programs that are continuously improving, data driven and supported with...more

Government Enforcers Focused on Coronavirus-related Actions

- Market participants should review and assess their compliance procedures to prevent and detect insider trading risks associated with COVID-19. - Companies should increase their vigilance regarding cybersecurity threats...more

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