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DOJ, SEC and CFTC Announce Parallel Criminal and Civil Charges Against Sam Bankman-Fried, FTX Trading and Alameda Research

On December 13, the U.S. Attorney’s Office for the Southern District of New York (the “U.S. Attorney’s Office”), the U.S. Securities and Exchange Commission (the “SEC”), and the U.S. Commodity Futures Trading Commission (the...more

Fifth Circuit Bombshell on SEC ALJs Raises Questions about DEA ALJs

In a decision that likely will reverberate throughout the administrative state, a three-judge panel of the United States Court of Appeals for the Fifth Circuit recently held in Jarkesy v. Securities and Exchange Commission...more

Signs, Signs, Everywhere a Sign: Changes in Store for SEC Enforcement under the Trump Administration

Even before President Trump’s nomination of Jay Clayton as the next Chairman of the Securities and Exchange Commission (“SEC” or “Commission”), signs have been appearing that changes are afoot within the Division of...more

The Tenth Circuit Rules SEC Administrative Judges Are Unconstitutional, Setting Up Potential Supreme Court Review

The constitutionality of the SEC’s in-house administrative proceedings is in doubt following the 10th Circuit Court of Appeals’ ruling in Bandimere v. SEC. In Bandimere, a three-judge panel held, by a 2-1 decision, that SEC...more

The SEC Retains its House Advantage During Administrative Proceedings

Amendments to the Rules of Practice Do Little to Address Criticism that the Deck is Stacked - Facing pressure from industry practitioners and in the wake of constitutional challenges in multiple jurisdictions, the...more

New DOJ Policy Regarding Individual Accountability for Corporate Wrongdoing

On September 9, 2015, the U.S. Department of Justice announced a new policy regarding individual accountability for corporate misconduct. The policy, described in a memo authored by Deputy Attorney General Sally Yates,...more

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