Dorsey & Whitney LLP | USA | 20 Apr 2022
Earnings management has long been a key concern for the Commission and its Enforcement Division. While the agency has in recent years made various…
Dorsey & Whitney LLP | USA | 24 Aug 2016
The Commission’s Municipalities Continuing Disclosure Cooperation Initiative has been a significant success. Under the Initiative the agency has filed…
Dorsey & Whitney LLP | USA | 11 Nov 2015
New York Attorney General (“NY AG”) Eric T. Schneiderman may be leading the way again. In the past, the office pursued investigations using New…
Dorsey & Whitney LLP | Australia, Hong Kong, United Kingdom, etc. | 19 Sep 2014
The Commission continued with broken windows this week. Twenty Rule 105 short selling cases were filed in a group. Last week another group of broken…
Dorsey & Whitney LLP | USA | 17 Sep 2014
The theory of "broken windows," the enforcement approach being pursued by the SEC, is that prosecuting all violations large and small creates…
Dorsey & Whitney LLP | USA | 16 Sep 2014
The foreign payments cases held the organization and the individuals involved accountable while improving corporate governance for the benefit of the…
Dorsey & Whitney LLP | USA | 14 Sep 2014
The preliminary inquiry was followed by formal SEC investigations early in 1974. The resulting cases would become known as the “illicit or foreign…
Dorsey & Whitney LLP | USA | 12 Sep 2014
The SEC continued with its “broken windows” approach to enforcement this week, filing a group of 34 actions based on the failure to file either a…
Dorsey & Whitney LLP | USA | 11 Sep 2014
Broken Windows is the enforcement strategy adopted by the SEC as part of its "prosecute every violation big and small" approach in an effort to…
Dorsey & Whitney LLP | USA | 10 Sep 2014
Building on an undercover sting operation, the SEC filed an enforcement action against two individuals and their controlled entity. They are alleged…