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SEC Enforcement in Financial Reporting and Disclosure: 2019 Mid-Year Update

USA - August 5 2019 In May 2019, the SEC completed its second full year under the Stewardship of Chairman Jay Clayton. Unlike the “broken windows” philosophy1 Of Chair...

David Woodcock, Shamoil T. Shipchandler, Jules H. Cantor, Henry Klehm III.

FINRA Clarifies When Credit for Extraordinary Cooperation Will Be Awarded in Investigations

USA - July 5 2019 In recent years, broker-dealers have been seeking further transparency from the Financial Industry Regulatory Authority...

David P. Bergers, Laura S. Pruitt, Stephen J. Obie.

Raising the Bar on "Willful" Securities Law Violations

USA - May 13 2019 The D.C. Circuit’s decision is significant because certain SEC statutes require a finding of willfulness...

Sarah L. Levine, Laura S. Pruitt, Harold K. Gordon.

CFTC Issues Advisory on Self-Reporting of Foreign Corrupt Practices for Non-Registrants

USA - March 21 2019 The Advisory is part of the agency's broader commitment to provide "incentives for companies and individuals to engage in ethical corporate behavior...

Jayant W. Tambe, Ryan J. Andreoli, Stephen J. Obie.

SEC Highlights Need to Remediate ICFR Material Weaknesses

USA - February 11 2019 While the SEC's Financial Reporting and Audit Group has been...

David Woodcock, Sarah L. Levine, David P. Bergers, Henry Klehm III.