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SEC Dismisses In-House Proceedings Against Accountants Following Jarkesy

In the wake of the U.S. Supreme Court's recent Jarkesy decision, the U.S. Securities and Exchange Commission ("SEC") dismissed two contested Rule 102(e) proceedings against accountants, suggesting that the agency believes...more

SEC v. Jarkesy: Defendants Entitled to Jury Trial in SEC Fraud Actions

Seventh Amendment entitles defendants to jury trials when the SEC seeks civil penalties for securities fraud. ...more

U.S. Supreme Court Bars Liability for "Pure Omissions" Under Section 10(b) of Securities Exchange Act

The United States Supreme Court in Macquarie Infrastructure Corp. v. Moab Partners, L.P., No. 22-1165, ruled that a corporation is not liable under Section 10(b) of the Securities Exchange Act of 1934 and Rule 10b-5 for...more

2023 Securities Litigation Year in Review

During 2023, securities lawsuit filings rose for the first time in four years. Settlements declined last year; there were nine mega-settlements of more than $100 million, including a $1 billion settlement. Case filings...more

Second Circuit Provides Valuable Guidance on Application of the Supreme Court's Price-Impact "Mismatch" Framework

In Short - The Situation: The United States Court of Appeals for the Second Circuit recently decertified a class of stockholders who alleged that Goldman Sachs maintained an inflated share price by making...more

Insider Trading Enforcement in 2022

Each year, the Department of Justice ("DOJ"), the Securities and Exchange Commission ("SEC"), and in recent years, the Commodity Futures Trading Commission ("CFTC") dedicate substantial resources to investigating and...more

Your Company Has Been Sued for Securities Fraud—Now What?

According to the Stanford Law School/Cornerstone Research Securities Class Action Clearinghouse, each year since 2001, with just one exception (2006), investors have filed more than 150 securities fraud class actions in the...more

Fifth Circuit Finds SEC Administrative Proceedings Unconstitutional

On May 18, 2022, the Court of Appeals for the Fifth Circuit ruled that key aspects of the SEC's in-house enforcement regime for securities fraud cases were unconstitutional. The decision, Jarkesy v. SEC, has significant...more

SEC Brings Landmark Suit Over Alleged Misrepresentations in ESG-Related Documents

The U.S. Securities and Exchange Commission's ("SEC") Climate and ESG Task Force has filed one of its most significant enforcement matters to date. On April 28, 2022, the SEC brought an action in the U.S. District Court for...more

SEC Announces Settlement of Fraud Case Without Requiring Financial Penalty in Recognition of Company's Substantial Cooperation

On January 28, 2022, the U.S. Securities and Exchange Commission ("SEC") announced a settled fraud case with HeadSpin, Inc., a technology start-up, that allegedly engaged in a scheme to boost the company's valuation to more...more

SEC Enforcement in Financial Reporting and Disclosure: Year-End 2021 Update

We are pleased to present our year-end update on financial reporting and issuer disclosure enforcement activity. This White Paper primarily focuses on the U.S. Securities and Exchange Commission’s (“SEC”) enforcement activity...more

2020 Securities Litigation Year in Review

2020 was another active year for securities litigation in the United States. Federal securities class actions continued to be filed at record levels notwithstanding the COVID-19 pandemic. In fact, a number of those newly...more

FCPA 2018 Year In Review

Under the second year of the Trump Administration, the biggest story was the increase of corporate declinations one year after the DOJ adopted a permanent FCPA policy incentivizing self-disclosure, cooperation, and...more

The Perils of Well-Intentioned Deception: Insider Trading Case Highlights Challenges Facing Public Companies

The Situation: Despite Equifax's use of a cover story to keep employees from learning it was the victim of a serious data breach, a then-employee allegedly figured it out and made illegal securities trades based on the...more

Supreme Court Dismisses Important Securities Case on Issue Likely to Arise Again

On June 18, 2018, the U.S. Supreme Court dismissed Leidos v. Indiana Public Retirement System, a securities case that raised important and unsettled issues about the scope of liability under Section 10(b) of the Securities...more

Second Circuit Court of Appeals Expands Insider Trading Liability

On August 23, 2017, the Second Circuit Court of Appeals affirmed the insider trading conviction of Matthew Martoma, a former portfolio manager for SAC Capital Advisors LLP ("SAC Capital"). In doing so, the court overturned...more

U.S. Supreme Court Significantly Limits SEC's Power to Recover Disgorgement

On June 5, 2017, in an unanimous ruling in Kokesh v. SEC, No. 16-529, the United States Supreme Court significantly limited the breadth of the Securities and Exchange Commission's primary enforcement tool. The Court held that...more

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