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...
FinCEN released a proposed rule that would identify international convertible virtual currency mixing as a class of transactions of “primary money laundering concern” – a designatio...
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...
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...
The SEC lost a game point in its case against Ripple Labs when a federal court ruled that several categories of XRP token sales were not securities transactions. If adopted by other court...
Davis Polk partners Robert Cohen and Fiona Moran and associate Abigail Cooper authored “A decade in review: SEC cryptocurrency enforcement – Where we have been and where we are going ...
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...
On April 14, a unanimous Supreme Court held that parties can challenge the constitutionality of the FTC’s and SEC’s administrative proceedings in federal court before an agency review...
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...
