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Insider Trading Enforcement

Cooley LLP

The Life of Former SEC Chair (and Corp Fin Director) Manny Cohen

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Recently, I blogged about the 20 Corp Fin Directors we’ve had at the SEC (we haven’t heard yet who will be the new Corp Fin Director) – and it got me thinking about Manny Cohen, whom many of us don’t know much about since he...more

White & Case LLP

SEC Enforcement Year-End Overview

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2024 marks the final year of Gary Gensler's term as Chair of the U.S. Securities and Exchange Commission ("SEC"). The Gensler SEC has been aggressive on both the enforcement and rulemaking fronts. In response, the financial...more

Proskauer - Regulatory & Compliance

Proskauer Hedge Fund Trading Guide 2024 – Chapter 3: Special Issues under Sections 13(d) and 16 for Hedge Funds

Proskauer’s Practical Guide to the Regulation of Hedge Fund Trading Activities offers a concise, easy-to-read overview of the trading issues and questions we commonly encounter when advising hedge funds and their managers. It...more

A&O Shearman

UK Financial Conduct Authority Policy Statement on Changes to Financial Crime Guide

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The U.K. Financial Conduct Authority has published a policy statement on changes to its financial crime guide, following its consultation in April. The changes cover the following areas: (i) sanctions—to reflect information...more

Seward & Kissel LLP

SEC Announces Enforcement Results for Fiscal Year 2024

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On November 22, 2024, the SEC released its fiscal year 2024 enforcement statistics.  According to the accompanying press release, the SEC filed 583 total enforcement actions—431 of them standalone actions—while obtaining $8.2...more

Morrison & Foerster LLP

What to Expect from the SEC During a Second Trump Administration?

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Given the recent news about President-Elect Trump’s cabinet appointments , it is a safe bet that the SEC Division of Enforcement’s priorities will change under the new administration. Under President Biden, SEC Chair Gary...more

Cozen O'Connor

Navigating the Future: Key Takeaways & Insights from the 2024 Securities Enforcement Forum Central

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One of the concerns following the Supreme Court’s ruling in SEC v. Jarkesy was that other agencies may face similar collateral attacks to its administrative proceedings. While the full impact of Jarkesy remains an open...more

Snell & Wilmer

SEC v. Panuwat: The SEC’s “Shadow Trading” Paradigm

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On April 5, 2024, the Securities and Exchange Commission (“SEC”) obtained its first favorable insider trading verdict based on “shadow trading.” The SEC filed suit against Matthew Panuwat, claiming that he accessed highly...more

K&L Gates LLP

Shedding Light on "Shadow Trading" and What Companies Should Do Now

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The concept of insider trading under the federal securities laws has evolved over the years, at times in unexpected ways. Current insider trading standards have developed through case law and administrative actions applying...more

Vinson & Elkins LLP

Cooperation and Compliance: Navigating Artificial Intelligence at the Securities Enforcement Forum

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On May 23, 2024, the Securities Enforcement Forum West debuted its first-ever panel on the impact of artificial intelligence (“AI”) on securities enforcement, regulation, compliance, and practice, signaling an increased focus...more

White & Case LLP

“Novel” or Not: the SEC and DOJ’s Expansion of Insider Trading to “Shadow Trading” and 10b5-1 Plans Survive Their Days in Court

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On April 5, 2024, the U.S. Securities and Exchange Commission ("SEC") won a jury verdict in its first "shadow trading" insider trading action. Only a few weeks before this verdict, a court denied a motion to dismiss a...more

Akin Gump Strauss Hauer & Feld LLP

The ‘Eddie Murphy Rule’ Earns Its Moniker: The CFTC Brings a Classic Insider Trading Case

While it took a few decades to surface, the fact pattern set forth in the movie “Trading Places” has finally come to pass. However, instead of the alleged wrongdoers bribing a U.S. government official for a sneak peek at...more

Proskauer - Corporate Defense and Disputes

SEC Defeats Summary Judgment in Insider-Trading Suit Alleging “Shadow Trading”

The SEC defeated a motion for summary judgment brought by a defendant whom the SEC accused of engaging in insider trading based on news about a not-yet-public corporate acquisition when he purchased securities of a company...more

Winstead PC

SEC and DOJ Go On An Insider-Trading Enforcement Spree

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Last week, the U.S. Securities and Exchange Commission brought five insider-trading cases against a slew of individuals. The U.S. Attorney’s Office for the Southern District of New York also announced parallel criminal...more

Pillsbury Winthrop Shaw Pittman LLP

SEC Enforcement: 2022 Year in Review

On the heels of record-breaking enforcement in 2022, expect continued aggressive pursuit of Chair Gensler’s priorities in 2023. The SEC will continue to bring its considerable resources to bear to address ESG-related...more

Katten Muchin Rosenman LLP

SEC Announces Year-End Enforcement Results, Highlighting Record-Breaking Penalties - Capital Markets Compass | Issue 4

On November 15, the Securities and Exchange Commission (the SEC) released its summary of enforcement actions brought during the 2022 fiscal year, announcing that in 2022 the SEC filed 760 enforcement actions and recovered an...more

Oberheiden P.C.

SEC Exam Priorities for 2023

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Find Out What Companies and Investment Firms Need to Know about the SEC’s Exam Priorities for 2023 - Each year, the U.S. Securities and Exchange Commission (SEC) publishes its annual examination priorities. This report...more

Proskauer - Corporate Defense and Disputes

SEC Enforcement Director and SDNY/EDNY Officials Address Enforcement Priorities

SEC Division of Enforcement Director Gurbir Grewal and several high-ranking officials from the U.S. Attorney’s Offices for the Southern and Eastern Districts of New York and the FBI spoke on November 29, 2022 at a conference...more

Morrison & Foerster LLP

SEC Action Against Cheetah Mobile Execs Shows Rule 10b5-1 Plans Are Not a Get Out of Jail Free Card

On September 21, 2022, the Securities & Exchange Commission announced a settled enforcement action against two executives of China-based mobile internet company Cheetah Mobile, Inc. The SEC alleged that Sheng Fu, Cheetah...more

Harris Beach Murtha PLLC

When Cryptocurrency Gets Too Cryptic: First Charges of Insider Trading Foreshadow Heightened Government Scrutiny

Three individuals are facing criminal and civil charges in the first-ever cryptocurrency insider trading scheme. In its July 21, 2022 announcement, the U.S. Attorney for the Southern District of New York (“SDNY”) alleges that...more

Morrison & Foerster LLP

Commodities Futures Trading Commission and National Futures Association Announce Enforcement Trends and Priorities

The Commodities Futures Trading Commission (CFTC) and the National Futures Association (NFA) have outlined a broad enforcement agenda that aims to address recent commodities marketplace trends....more

Vinson & Elkins LLP

Novel Enforcement for Novel Schemes: Emerging Trends in Securities Enforcement

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This was the main takeaway from the Securities Enforcement in the Biden Administration panel at the American Bar Association’s 37th National Institute on White Collar Crime, which included among its speakers Erin Schneider,...more

Nutter McClennen & Fish LLP

Nutter Securities Enforcement Update: March 1, 2022

The Nutter Securities Enforcement Update is a periodic summary of noteworthy recent securities enforcement activity, settlements, decisions, and charges. ...more

Faegre Drinker Biddle & Reath LLP

SEC’s Director of Enforcement Unexpectedly Resigns Just Days after Taking the Job: Reminiscent of Previous Resignation by former...

Alex Oh, U.S. Securities and Exchange Commission (SEC) Chair Gary Gensler’s pick for the agency’s Director of the Division of Enforcement, unexpectedly resigned on Wednesday amid growing criticism for her decades-long work as...more

Latham & Watkins LLP

Insider Trading in Commodities Markets: An Evolving Enforcement Priority

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The CFTC and the DOJ both now pursue enforcement actions against trading in commodities based on misappropriation of confidential information. Among the many changes resulting from the Dodd-Frank Wall Street Reform and...more

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