Topic
Enforcement
987 published works
Corporate & Financial Weekly Digest
CFTC Issues Guidance on Compliance Program Evaluations in Connection With Enforcement Matters
By Kevin M. Foley, James M. Brady
On September 10, the Commodity Futures Trading Commission’s Division of Enforcement (Division) issued guidance outlining factors to consider when evaluating compliance programs as part of enforcement matters. The Division had…
Ad Law Access
Illinois Court Dismisses Neora’s Declaratory Judgment Suit against FTC on Jurisdictional Grounds
By John E. Villafranco, Donnelly McDowell
Turns out the best defense may not be a good offense, at least when litigating against the FTC. The Northern District of Illinois yesterday rejected an attempt by multi-level marketer…
Government Contracts & Investigations Blog
Ninth Circuit Reverses SEC Disgorgement Award and Remands in First Decision Post-Liu
By Christopher Bosch, Sarah Aberg
For the first time outside of the originating case itself, a federal appeals court was called upon to apply the principles governing disgorgement in SEC enforcement actions established by the…
FCPA Professor
Further To The SEC’s Inconsistent Approach To Enforcing The FCPA’s Books And Records And Internal Controls Provisions
By Mike Koehler
Other than this website (see here, here, here, here, here, here and here), there seems to be little focus on the SEC’s inconsistent approach to enforcing the FCPA’s books and records and internal controls provisions. Which is…
Inside Political Law
The FEC Appears to be Exercising its Powers Without a Quorum
By Robert Lenhard, Peter Koski
Over the past 10 days, the FEC has been quietly exercising authority reserved for when at least four Commissioners vote in favor of an action. Since July 3, however, the…
RopesDataPhiles
NYDFS Brings its First Cybersecurity Enforcement Action
By Ropes & Gray
On July 22, 2020, New York’s Department of Financial Services (NYDFS) filed its first cybersecurity enforcement action against First American Title Insurance Company (First American), seeking civil monetary penalties for…
SEC Actions
This Week In Securities Litigation (Week of August 10, 2020)
Co-Director of Enforcement Steven Peikin announced his resignation. Mr. Peikin joined the staff shortly after Chairman Clayton, from Sullivan and Cromwell. Consideration is being given to again directing that audit…
SEC Actions
The Second Quarter: A Review of SEC Enforcement
In the second quarter of 2020 as the pandemic began to unfold the Enforcement Division continued to file new actions. Indeed, the agency filed a larger number of actions in…
Broker- Dealer Law Corner
FINRA ♥ Rule 8210
By Alan Wolper, UB Greensfelder
I hope that you have had the chance to enjoy Jessica Hopper’s paean to Rule 8210 in her recent blog posted on FINRA’s website. Very disturbing, and for all the…
The Daily Intake
USDA’s Proposed Rule Strengthens the Enforcement and Oversight of Organics
On July 9, 2020, USDA’s Agricultural Marketing Service unveiled an unpublished draft of Strengthening Organic Enforcement, which is a new rule for the National Organic Program aimed at bolstering enforcement…