In this edition of the newsletter, we discuss enforcement developments at the agencies in October 2023. Last month, the SEC filed 13 actions and the CFTC filed three, against a combined t...
After receiving board approval to buy back stock under a 10b5-1 plan, a company interpreted Rule 10b5-1 in a manner with which the SEC disagreed. The SEC did not allege that the company t...
On October 17, 2023, CFTC Director of Enforcement Ian McGinley signaled a more aggressive approach by the agency in new enforcement guidance addressing penalties, admissions, the impositi...
On Wednesday, Deputy Attorney General Monaco announced new DOJ guidance providing a safe harbor to avoid criminal prosecution for companies that identify and disclose misconduct that occu...
Webinar
1.0 CA - General; NY - Professional Practice / Practice Management
Please join us as we review key developments from the first half of the year and the outlook for the second half in anti-corruption and FCPA enforcement and related areas. Topics will inc...
The final rules require current reporting of cybersecurity incidents and annual risk management disclosure for public companies that are likely to compound compliance costs and enforcemen...
In its second enforcement action under the Health Breach Notification Rule, the Federal Trade Commission (FTC) reinforces the administration’s focus on protecting reproductive health da...
In recent speeches, Deputy Attorney General Lisa Monaco and Principal Associate Deputy Attorney General Marshall Miller laid out how the DOJ uses active corporate criminal enforcement and...
The SEC proposed a broad suite of new cybersecurity rules for many market participants, including policies and procedures to address cybersecurity risk, written incident response programs...
Last week, DOJ announced much-anticipated guidance on compensation clawbacks and the use of messaging apps, as well as modifications to its monitorship policies. The guidance provides com...
