Each month, we publish a roundup of the most important SEC enforcement developments for busy in-house lawyers and compliance professionals. This month, we examine the following matters:
• An SEC complaint alleging a Georgia...more
8/25/2025
/ Blockchain ,
Corporate Counsel ,
Digital Assets ,
Enforcement Actions ,
Financial Industry Regulatory Authority (FINRA) ,
Foreign Corrupt Practices Act (FCPA) ,
Fraud ,
Insider Trading ,
Investment Adviser ,
Investors ,
Ponzi Scheme ,
Popular ,
Securities and Exchange Commission (SEC) ,
Securities Fraud ,
Securities Violations ,
Voluntary Dismissals
Last week, New York State Department of Financial Services (NYDFS) left no doubt that it will continue to actively regulate cryptocurrency despite the pullback in law enforcement efforts by the federal government, including...more
8/13/2025
/ Anti-Money Laundering ,
BitLicense ,
Consent Order ,
Cryptocurrency ,
Digital Assets ,
Enforcement Actions ,
New York ,
NYDFS ,
Office of Foreign Assets Control (OFAC) ,
Regulatory Oversight ,
Regulatory Requirements ,
Stablecoins
On July 30, 2025, the White House released a 166-page report titled “Strengthening American Leadership in Digital Financial Technology” (the “Report”).[1] Authored by a working group of cabinet members and federal agency...more
8/7/2025
/ AML/CFT ,
Banking Sector ,
Biden Administration ,
Blockchain ,
CFTC ,
Cryptocurrency ,
Cybersecurity ,
Decentralized Finance (DeFi) ,
Department of Justice (DOJ) ,
Digital Assets ,
Enforcement Actions ,
Financial Regulatory Reform ,
FinTech ,
IRS ,
Multi-Factor Authentication ,
NIST ,
Popular ,
Regulatory Reform ,
Securities and Exchange Commission (SEC) ,
Securities Exchange Act ,
Stablecoins ,
U.S. Treasury
On May 14, 2025, Deputy Enforcement Director Antonia Apps told those gathered at an anti‑money laundering conference in Washington, D.C. to expect a more measured approach from SEC Enforcement. That may include, she...more
6/25/2025
/ Anti-Money Laundering ,
Broker-Dealer ,
Corporate Counsel ,
Cryptocurrency ,
Enforcement Actions ,
Financial Industry Regulatory Authority (FINRA) ,
Fraud ,
International Chamber of Commerce (ICC) ,
Investment Adviser ,
Investment Management ,
Penalties ,
Popular ,
Real Estate Development ,
Securities and Exchange Commission (SEC) ,
Securities Fraud ,
Securities Regulation ,
Settlement
Each month, we publish a roundup of the most important SEC enforcement developments for busy in-house lawyers and compliance professionals. For the month when Paul Atkins was sworn in as SEC Chairman, we examine:
• The SEC’s...more
5/28/2025
/ Corporate Counsel ,
Cryptocurrency ,
Enforcement ,
Enforcement Actions ,
Fraud ,
Investment ,
Investment Adviser ,
Investment Funds ,
Receivership ,
Securities and Exchange Commission (SEC) ,
Securities Fraud ,
Securities Regulation ,
Securities Violations ,
Stablecoins
On April 17, 2025, three operating divisions (the “Operating Divisions”) of the U.S. Commodity Futures Trading Commission (“CFTC”) and the Division of Enforcement (“DOE”) provided guidance in CFTC Letter 25-13 (the...more
4/29/2025
/ CFTC ,
Disclosure Requirements ,
Enforcement Actions ,
Financial Crimes ,
Materiality ,
New Guidance ,
Penalties ,
Regulatory Requirements ,
Reporting Requirements ,
Risk Management ,
Self-Reporting
Each month, we publish a roundup of the most important SEC enforcement developments for busy in-house lawyers and compliance professionals. This month, we examine:
•An SEC action alleging an insider trading scheme and...more
4/23/2025
/ Climate Change ,
Corporate Counsel ,
Enforcement Actions ,
Fiduciary Duty ,
Insider Trading ,
Investment Adviser ,
Ponzi Scheme ,
Private Funds ,
Regulatory Reform ,
Securities and Exchange Commission (SEC) ,
Securities Fraud
On April 7, 2025, Deputy Attorney General Todd Blanche issued a memo (the “Blanche Memo”) announcing the Trump administration’s Department of Justice (“DOJ”) refocus of enforcement policies related to investigations and...more
4/11/2025
/ CFTC ,
Corporate Counsel ,
Crypto Exchanges ,
Cryptocurrency ,
Department of Justice (DOJ) ,
Digital Assets ,
Enforcement Actions ,
Money Laundering ,
Regulatory Violations ,
Securities Fraud ,
Trump Administration
On April 4, 2025, the staff of the U.S. Securities and Exchange Commission (SEC or “Commission”) Division of Corporation Finance (“Staff”) issued a statement on stablecoins (the “Stablecoin Statement”), outlining the Staff’s...more
4/9/2025
/ Cryptoassets ,
Digital Assets ,
Enforcement Actions ,
Financial Markets ,
Howey ,
Investment Contract ,
Popular ,
Regulatory Requirements ,
Securities and Exchange Commission (SEC) ,
Securities Regulation ,
Stablecoins
On March 14, 2025, a judge in the U.S. District Court for the District of Maryland declined to grant a temporary injunction to the City of Baltimore and the Economic Action Maryland Fund. The plaintiffs had requested an...more
3/21/2025
/ Bank Secrecy Act ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Enforcement Actions ,
FDIC ,
Federal Reserve ,
Financial Regulatory Reform ,
FinTech ,
Military Lending Act ,
OCC ,
Regulatory Agenda ,
Stablecoins
To issue a subpoena for documents or testimony, Enforcement staff must first obtain a formal order. A formal order authorizes SEC staff “to administer oaths and affirmations, subpoena witnesses, compel their attendance, take...more
Each week of the first 100 days of the new Trump administration, we will publish updates on key federal financial services regulatory and related developments.
This week, we review the following developments as of Wednesday:...more
On February 27, 2025, the staff of the Securities and Exchange Commission’s Division of Corporate Finance (the “staff”) released its views on “meme coins,” stating that under certain circumstances, the offer and sale of “meme...more
The Advisory sets out factors that the Enforcement Division will use to rate self-reporting and cooperation. This rating places a company or individual within a “tier” used to determine the Mitigation Credit amount available....more
On January 17, 2025, a few days before the presidential inauguration, the SEC reported a record-breaking first quarter of fiscal year 2025 (October through December 2024) with 200 total enforcement actions, including 118...more
2/27/2025
/ Artificial Intelligence ,
Compliance ,
Corporate Counsel ,
Corporate Governance ,
Cryptocurrency ,
Disclosure Requirements ,
Enforcement Actions ,
Fraud ,
Investment Adviser ,
Securities and Exchange Commission (SEC) ,
Securities Regulation ,
Securities Violations ,
Whistleblowers
On February 7, 2025, newly confirmed Office of Management and Budget (OMB) director Russell Vought replaced Treasury Secretary Scott Bessent as acting director of the CFPB....more
2/14/2025
/ CFTC ,
Consumer Financial Protection Bureau (CFPB) ,
Cryptocurrency ,
Enforcement Actions ,
Federal Funding ,
Federal Reserve ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
OMB ,
Regulatory Agenda
Each month, we publish a roundup of the most important SEC enforcement developments for busy in-house lawyers and compliance professionals. This month, we examine:
•Insider trading charges against a professor overseeing...more
1/28/2025
/ Compliance ,
Corporate Counsel ,
Corporate Governance ,
Cybersecurity ,
Disclosure Requirements ,
Enforcement Actions ,
Financial Crimes ,
Financial Services Industry ,
Fraud ,
Insider Trading ,
Perks ,
Risk Management ,
Securities and Exchange Commission (SEC) ,
Securities Regulation ,
Settlement
The SEC continues to leave its mark as a federal cybersecurity enforcer and closed out the year by charging another company with making misleading statements about a cybersecurity attack and failing to maintain cyber-related...more
1/23/2025
/ Cyber Attacks ,
Cybersecurity ,
Data Breach ,
Data Privacy ,
Disclosure Requirements ,
Enforcement Actions ,
Financial Institutions ,
Form 10-K ,
Publicly-Traded Companies ,
Risk Management ,
Securities Act of 1933 ,
Securities and Exchange Commission (SEC) ,
Securities Fraud
On December 20, 2024, the Securities and Exchange Commission (SEC or the “Commission”) announced charges against several entities that failed to file a Form D within 15 days of a private sale of securities. These entities,...more
1/8/2025
/ Civil Monetary Penalty ,
Compliance ,
Enforcement Actions ,
Filing Deadlines ,
Filing Requirements ,
Form D Filing ,
Investment Adviser ,
Private Equity ,
Private Funds ,
Registration Requirement ,
Regulation D ,
Reporting Requirements ,
Securities and Exchange Commission (SEC) ,
Securities Regulation ,
Securities Violations
Each month, we publish a roundup of the most important SEC enforcement developments for busy in-house lawyers and compliance professionals. This month, we examine:
•Accounting fraud charges for allegedly concealing costs;...more
11/29/2024
/ Accounting Fraud ,
Aerospace ,
Artificial Intelligence ,
Bribery ,
Civil Monetary Penalty ,
Cryptocurrency ,
Enforcement Actions ,
Environmental Social & Governance (ESG) ,
ETFs ,
Foreign Corrupt Practices Act (FCPA) ,
Fraud ,
Greenwashing ,
Misleading Statements ,
Popular ,
Securities and Exchange Commission (SEC) ,
Unregistered Brokers
Each month, we publish a roundup of the most important SEC enforcement developments for busy in-house lawyers and compliance professionals. This month, we examine:
•Judge Paul Engelmayer’s decision on defendants’ motion to...more
8/22/2024
/ Broker-Dealer ,
Corporate Counsel ,
Cryptocurrency ,
Decentralized Finance (DeFi) ,
Enforcement Actions ,
Financial Industry Regulatory Authority (FINRA) ,
Hedge Funds ,
Illegal Trading ,
Investment Adviser ,
Investment Firms ,
Online Platforms ,
SEC v Jarkesy ,
Securities and Exchange Commission (SEC) ,
SolarWinds
On June 27, 2024, the Supreme Court decided in SEC v. Jarkesy that where the Securities and Exchange Commission (“SEC”) brings enforcement actions for civil penalties, it must do so in the federal courts, as opposed to before...more
7/1/2024
/ Administrative Authority ,
Administrative Law Judge (ALJ) ,
Administrative Proceedings ,
Civil Monetary Penalty ,
Constitutional Challenges ,
Enforcement Actions ,
Jury Trial ,
NLRB ,
SCOTUS ,
SEC v Jarkesy ,
Securities and Exchange Commission (SEC) ,
Securities Fraud ,
Securities Regulation ,
Separation of Powers ,
Seventh Amendment
On April 5, 2024, a jury in California federal court found a former corporate executive liable for insider trading in SEC v. Panuwat, a novel enforcement action involving a theory known as “shadow trading.” In Panuwat, the...more
Each month we publish a roundup of the most important SEC enforcement developments for busy in-house lawyers and compliance professionals. This month, we examine:
•The SEC’s approval of spot bitcoin ETPs; -
•SEC charges...more
2/27/2024
/ Bitcoin ,
Corporate Counsel ,
Cryptocurrency ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Foreign Corrupt Practices Act (FCPA) ,
Initial Public Offering (IPO) ,
PCAOB ,
Ponzi Scheme ,
Securities and Exchange Commission (SEC) ,
Securities Exchange Act ,
Special Purpose Acquisition Companies (SPACs)
Each month, we publish a roundup of the most important SEC enforcement developments for busy in-house lawyers and compliance professionals. This month, we examine:
• The SEC’s announcement of its Fiscal Year 2023 enforcement...more
12/18/2023
/ Charter Communications ,
Constitutional Challenges ,
Corporate Counsel ,
Corporate Governance ,
Cryptocurrency ,
Cyber Crimes ,
Enforcement Actions ,
Hackers ,
Internal Controls ,
Remedies ,
SCOTUS ,
Securities and Exchange Commission (SEC) ,
Securities Exchange Act ,
Securities Regulation ,
Share Buybacks ,
Whistleblowers