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
The US Securities and Exchange Commission (SEC) has sharpened its focus on “cherry-picking,” a practice in which investment advisers allocate profitable trades to favored accounts – sometimes their own – while assigning less...more
SEC v. Nagler is the second enforcement action charging an investment adviser with undisclosed conflicts of interest since Chair Paul Atkins began his tenure on April 21, 2025. The Securities and Exchange Commission (SEC)...more
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
A recent ruling may raise the bar for the Securities and Exchange Commission (SEC) in charging registered investment advisers for omissions of potential conflicts and seeking disgorgement, giving the defense bar additional...more
The SEC’s recent order instituting administrative and cease-and-desist proceedings (OIP) against registered investment advisers Two Sigma Investments LP and Two Sigma Advisers LP illustrates significant risks for investment...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
On February 14, 2025, the Securities and Exchange Commission (“SEC”) published a settled Administrative Proceeding Order with One Oak Capital Management, LLC (“One Oak”) and Michael DeRosa. DeRosa served as an investment...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 January 16, 2025, the Securities and Exchange Commission (“SEC”) filed a settled enforcement action against a pair of related investment advisers (the “Investment Adviser”) for allegedly breaching their fiduciary duties by...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
Last week, the U.S. Securities and Exchange Commission announced that it had settled "charges" against two private companies and one registered investment adviser for failing to timely file Forms D for several unregistered...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
The Securities and Exchange Commission (SEC) recently brought settled enforcement actions against two registered investment advisers for failing to establish, maintain, and enforce written policies and procedures reasonably...more
Three recent enforcement actions highlight the risks of failing to adhere to representations made to investors regarding ESG and biblically responsible investing strategies....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
Our Investment Funds and White Collar, Government & Internal Investigations Groups examine a recent Securities and Exchange Commission enforcement order involving control of inside information....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