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Fiscal Year 2024 in Review: Key Takeaways and Predictions from SEC Enforcement Actions Against US Public Companies

On November 22, 2024, the US Securities and Exchange Commission (SEC) released its enforcement results for fiscal year ("FY") 2024 (October 1, 2023 through September 30, 2024).1 While the next administration's approach to...more

SEC’s Action on Recyclability Statements Shows Continued Focus on ESG Related Claims

Notwithstanding recent reports that the Securities and Exchange Commission (“SEC”) has quietly disbanded its Climate and ESG Task Force,1 and while the SEC’s new climate-related disclosure rules remain stayed,2 the SEC’s...more

SEC Warns Individual Actors of Potential Liability for AI-Related Security Risk Disclosure Failures

Over the past few months, the Securities and Exchange Commission (the "SEC") has issued several warnings to companies to ensure accurate disclosure of the role and risks of artificial intelligence ("AI") in their businesses....more

SEC Enforcement Director Emphasizes Current Tools Exist for Combatting Inaccurate Environmental Disclosures

While there are news reports that the U.S. Securities and Exchange Commission ("SEC") is on the verge of issuing new climate related disclosure rules for public companies, the SEC's Director of the Division of Enforcement...more

Key Considerations for the 2023 Annual Reporting and Proxy Season Part II: Proxy Statement

Part I of our two-part Annual Memo series identified important considerations when preparing Annual Reports on Form 10-K in 2023. Part II of this memo below, describes our key considerations for 2023 Annual Meeting Proxy...more

ESG is increasingly critical in US M&A, but greenwashing concerns persist

Buyers are scrutinizing everything from an acquisition target’s projected greenhouse gas (GHG) emissions to ways in which a deal may impact their own climate mitigation strategies. In this regard, reliable and verifiable...more

SEC: The watchdog bares its teeth

The Securities and Exchange Commission (SEC) has followed through on its much publicized intention of more aggressive enforcement. For instance, in June, the regulator brought an accounting fraud action that included a...more

SEC to take tougher line on enforcement

New Securities and Exchange Commission Chair Gary Gensler has put scrutiny of SPACs and private funds at the top of his agenda - President Biden's appointment of Gary Gensler as Chair of the US Securities and Exchange...more

More Aggressive White Collar Enforcement Expected Under the Biden Administration

The first 100 days of President Biden's administration, not least its appointments to key leadership positions, suggest that it will investigate and pursue white collar cases much more aggressively than the Trump...more

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