10 For 10: Top Compliance Stories For the Week Ending March 15, 2025
Ep. 3 - The Art of Parallel Investigations (Part 2)
Episode 286 -- Matt Stankiewicz on the Ripple Decision and Celsius CEO Indictment
Blue Sky Laws: Defending State-Level Securities Violations
The Justice Insiders: The Administrative State is Not Your Friend - A Conversation with Professor Richard Epstein
Four Decision Points in SEC Securities Investigations
Crypto Enforcement Is Here, and Always Has Been
Cryptocurrency: The Regulator’s Perspective
Investment Management Roundtable Discussion – Regulatory and Enforcement Update
Each month, we publish a roundup of the most important SEC enforcement developments for busy in-house lawyers and compliance professionals. For the month when Paul Atkins was sworn in as SEC Chairman, we examine: • The SEC’s...more
On April 1, the U.S. Court of Appeals for the First Circuit vacated a summary judgment ruling in favor of the Securities and Exchange Commission (SEC) against Commonwealth Equity Services, LLC, also known as Commonwealth...more
The court rejects the SEC's per se materiality argument and requires proof of a causal connection between the defendant's allegedly inadequate disclosures and purported unlawful profits....more
On January 17, 2025, a few days before the presidential inauguration, the SEC reported a record-breaking first quarter of fiscal year 2025 (October through December 2024) with 200 total enforcement actions, including 118...more
As we head further into 2025, the landscape of SEC exams and enforcement is poised for significant shifts. How will the SEC adapt to emerging trends and evolving market dynamics? In the first issue of Beyond the Deal in 2025,...more
On 14 January 2025, the Securities and Exchange Commission (SEC) announced settled charges against three investment adviser representatives for acting as unregistered brokers in the sale of membership interests in certain...more
In this issue of our monthly Securities Enforcement Roundup, we highlight top securities enforcement developments and cases from December 2024. In December 2024: President-elect Trump nominated former SEC Commissioner Paul...more
On December 20, 2024, the Securities and Exchange Commission (SEC or the “Commission”) announced charges against several entities that failed to file a Form D within 15 days of a private sale of securities. These entities,...more
I recently wrote about the Securities and Exchange Commission's announcement that it had settled "charges" against several entities for failing to file time Forms D. One of the entities settling with the SEC is a registered...more
The Securities and Exchange Commission (SEC) announced on November 22, 2024, that three broker-dealers have agreed to settle charges for filing suspicious activity reports (SARs) that failed to include important, required...more
On November 22, the Securities and Exchange Commission (SEC) announced its enforcement results for fiscal year (FY) 2024. As compared to FY 2023, the Division of Enforcement (the division) reported a 26% decline in the total...more
After its fiscal year-end frenzy in September, the SEC relaxed slightly, with no new rule-making and fewer enforcement actions. So, I took a break last month and combined the October and November Roundups. (You’re welcome.)...more
On September 4, 2024, U.S. Securities and Exchange Commission ("SEC") Chair Gary Gensler reiterated concerns about artificial intelligence-related ("AI") disclosures and the need for companies to communicate accurately about...more
Social media marketing is an important form of advertising in our digital world, particularly with a target audience of younger investors. This has caught the eye of FINRA and the SEC....more
The SEC has increased its enforcement efforts against firms that are registered as broker-dealers and/or investment advisers for alleged violations of federal securities laws involving “off-channel communications.” Such...more
A broker-dealer (the “Dealer”) entered into a cease-and-desist order with the Securities and Exchange Commission for failing to maintain and enforce written policies and procedures reasonably designed to achieve compliance...more
The Securities and Exchange Commission (SEC) announced charges against 26 broker-dealers, investment advisers, and dually-registered firms for widespread and longstanding failures to maintain and preserve electronic...more
On June 11, the Securities and Exchange Commission (SEC) announced the first settled case in its ongoing review of collaborations between investment advisors and short publishers. The SEC fined affiliated investment advisors...more
The U.S. Court of Appeals for the Fifth Circuit held that the new SEC regulation of private fund advisers exceeded the agency's statutory authority....more
As a reminder, the Securities and Exchange Commission (SEC) and the National Association of Private Fund Managers (NAPFM) and the other Petitioners in the Private Funds Rules Litigation1 requested that the three-judge panel...more
Over the last several years, the Securities and Exchange Commission (“SEC”) has been laser-focused on the use of so-called “off-channel communications” in the financial services industry. On the theory that employees’ use of...more
The US Securities and Exchange Commission (“SEC”) recently settled charges against five registered investment advisers for violations of Rule 206(4)-1 (“Marketing Rule”) under the Investment Advisers Act of 1940, as amended...more
On April 3, 2024, the U.S. Securities and Exchange Commission (SEC) announced its first enforcement action against a registered investment adviser (RIA) with no ties to a broker-dealer regarding so-called “off-channel”...more
The Securities and Exchange Commission on Monday, March 18, 2024, entered into settlements with Delphia (USA) and Global Predictions, which agreed to pay civil penalties totaling $225,000 and $175,000, for “AI...more
On November 14, 2023, the SEC announced its enforcement results for fiscal year 2023, which ended on September 30, reporting the following key metrics and highlights...more