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SEC "Levels Up" in $35M Resolution of Alleged Whistleblower Protection Violations and Compliance Program Failures Against...

On February 3, the U.S. Securities and Exchange Commission (SEC) announced that video game developer Activision Blizzard, Inc. (Activision) agreed to pay $35 million to settle accusations that it violated whistleblower...more

SEC Settlement With McDonald's and Ex-CEO Signals Potential Expansion of Executive Compensation Disclosure Requirements

On January 9, the Securities and Exchange Commission (SEC) announced that it had reached a settlement with McDonald’s and its former CEO, Stephen Easterbrook, for charges stemming from McDonald’s 2019 termination of...more

SEC's Enforcement Results for FY 2022 Reflect Robust Enforcement and Record-Breaking Penalties

On November 15, the U.S. Securities and Exchange Commission (SEC) announced its enforcement results for fiscal year 2022, which featured the following key metrics...more

SEC Targets SPAC Conflicts of Interest

On September 6, investment advisory firm Perceptive Advisors LLC (Perceptive) agreed to a cease-and-desist order with the U.S. Securities and Exchange Commission (SEC) for failing to disclose alleged conflicts of interest...more

Plea Deal in First-Ever Cryptocurrency Insider Trading Case

In what the Manhattan federal prosecutors have touted as the first-ever guilty plea in an insider trading case involving cryptocurrency, the brother of a former Coinbase Global, Inc. (Coinbase) product manager pled guilty to...more

FINRA Issues Guidance Clarifying Liability for Chief Compliance Officers

On March 17, the Financial Industry Regulatory Authority (FINRA) issued a notice, clarifying when chief compliance officers (CCOs) will face liability as supervisors under FINRA Rule 3110. Under Rule 3110, member firms are...more

SEC Settlement Shows Commission’s Willingness to Waive Penalties for Investigatory Targets Focusing on Corrective Action

On January 28, the Securities and Exchange Commission (SEC or Commission) issued a press release, announcing the settlement of various fraud charges against a private technology company in light of their “significant remedial...more

SEC's New Insider "Shadow Trading" Theory Survives Its First Test

The Securities and Exchange Commission (SEC) is testing the bounds of insider trading laws (as previously reported here), and it recently survived the first challenge to its newest theory. On January 14, the U.S. District...more

Circuit Decision Provides SEC Roadmap to Seek Disgorgement Post-Liu

On October 12, the Fifth Circuit Court of Appeals affirmed a district court’s decision in SEC v. Blackburn, awarding disgorgement to alleged victims of a penny stock fraud scheme subject to SEC enforcement action. This...more

Delaware Court of Chancery Highlights Seriousness of Cybersecurity Concerns While Maintaining High Standard for Caremark Claims

On October 5, the Delaware Court of Chancery issued a decision in Firemen’s Retirement System of St. Louis v. Sorenson, et al., C.A. No. 2019-0965-LWW, dismissing breach of fiduciary duty claims brought against various...more

SEC Cases Offer Insight into Its Approach to Alleged COVID-19 Securities Fraud

A remote status conference was held June 28 for United States v. Mark Schena, currently pending in the U.S. District Court for the Northern District of California. In the recently unsealed superseding indictment, the SEC...more

SEC Enforcement Case Offers Important Lessons about Internal Controls and Stock Buybacks

The U.S. Securities and Exchange Commission (SEC) recently settled an enforcement action in which it found that a public company failed to develop and implement adequate controls around a stock buyback program. The action...more

Courts Ratchet Up Scrutiny of Implied Federal Agency Enforcement Tools

Federal agencies have long wielded a set of enforcement tools not explicitly provided for by statute. Restitution—used by the Federal Trade Commission (FTC) to secure billions from defendants—and disgorgement—the Securities...more

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