News & Analysis as of

Affiliates Enforcement Actions

Lowenstein Sandler LLP

The Importance of Complying with Private Fund Documents for Affiliate Transactions

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Private fund advisers continually balance their ongoing responsibility to ensure that the funds they advise comply with such funds’ governing documents and their responsibility to ensure their own compliance with applicable...more

Venable LLP

Lead Generation Scams in Healthcare: FTC Files Case Against Impersonator Ads

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On June 24, the Federal Trade Commission (FTC) filed a complaint in the U.S. District Court for the District of Maryland against Mercury Marketing, LLC, and several affiliated entities and individuals alleging that the...more

Latham & Watkins LLP

GDPR Fines to Be Determined by Reference to Global Turnover of Corporate Group

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The CJEU has decided that the maximum thresholds for GDPR fines should be calculated using the global turnover of the broader corporate group, not solely the infringing entity....more

Holland & Knight LLP

Trident Trust Investigation: Implications for Clients and Advisors

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The U.S. Department of Justice (DOJ) and the IRS have issued a John Doe summons targeting Trident Trust and related companies in three federal court cases. This development has significant implications for clients of Trident...more

BCLP

Recent SEC Enforcement Action Integrating Affiliated Advisers

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A recent Securities and Exchange Commission (“SEC”) settled enforcement action serves as an excellent reminder of the risk of operational integration to firms that operate multiple advisory entities, especially where one of...more

Goodwin

FTC Escalates Battle Against PBMs With Complaint on Insulin Pricing

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FTC’s challenge is the culmination of years of investigation, but choice of venue and theories of harm reveal potential weaknesses....more

Hudson Cook, LLP

CFPB Takes Action Against Fintech Company for Alleged Withholding of Consumer Refunds

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On May 7, 2024, the CFPB imposed a total of $4.6 million in redress and fines on the Company for allegedly withholding account-closure refunds to its consumers for an unreasonable amount of time....more

BCLP

First “Insider Trading” Case Goes From Bad to Worse for CFTC

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On January 8, 2024, the U.S. Court of Appeals for the Fifth Circuit reversed a jury’s verdict in a Commodity Futures Trading Commission (“CFTC”) enforcement action against EOX Holdings, L.L.C. (“EOX”) and its employee, Andrew...more

Goodwin

SEC and CFTC Send Powerful Message With $2 Billion in Fines Related to Social Media and Text Recordkeeping Lapses

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​​​​​​​The SEC and CFTC recently charged 11 large financial institutions and their affiliates for failing to collect, monitor, and preserve communications over WhatsApp and other messaging services. These settlements follow a...more

Dorsey & Whitney LLP

Enforcement Standards Tighten on Private Insurers: Sutter Health Settles for $90 Million Following Dispute With DOJ

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On August 30, 2021, the Department of Justice (“DOJ”) announced that Sutter Health and several of its affiliated entities (“Sutter”) agreed to pay a total of $90 million to settle allegations that Sutter violated the False...more

Proskauer - The Capital Commitment

SEC Enforcers Continue to Focus on Undisclosed Fees

In a series of enforcement cases over the past few months, the SEC has continued to bring actions focused on undisclosed fees charged to clients. Many of these cases have charged firms with fraud and other violations based on...more

Latham & Watkins LLP

SFC Obtains Disqualification and Court Orders Against Hanergy’s Former Chairman and Current Directors

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The Court of First Instance’s decision has important implications for directors of listed companies when failing to act in the best interests of the company. Background - On July 15, 2015, the Securities and Futures...more

Skadden, Arps, Slate, Meagher & Flom LLP

"Skadden Energy Law Handbook: Fourth Edition (November 2016)"

Skadden’s Energy Regulation and Litigation Group is pleased to provide the fourth edition of the Skadden Energy Law Handbook, which includes a summary of recent developments. The handbook contains 16 chapters covering a broad...more

Nexsen Pruet, PLLC

The Consumer Financial Protection Bureau's case against Citibank for violations relating to credit card add-on products

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Today we’re taking a look at the CFPB’s recent enforcement case against Citibank, N.A. (“Citibank”) and two of Citibank’s subsidiaries, Department Stores National Bank (“DSNB”) and Citicorp Credit Services, Inc. (USA) (“CCSI...more

Foley & Lardner LLP

A Compilation of Enforcement and Non-Enforcement Actions

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As reported in the May 2014 edition of Legal News: Investment Management Update, the SEC has made cybersecurity readiness a high-priority item to review when it conducts examinations of registered broker-dealers and...more

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