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Bryan Cave: Recent SEC Decision Identifies Social Media and Outside Activity Risks for Investment Advisers And Broker-Dealers

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Recent SEC Decision Identifies Social Media and Outside Activity Risks for Investment Advisers And Broker-Dealers

Bryan Cave
January 14, 2013
3 pages

SEC Enforcement

Morgan Lewis: SEC Warns About Exemptive Order Compliance

May 17, 2013 SEC Enforcement Actions

Chapman and Cutler: Securities and Exchange Commission Cease-and-Desist Order Against the City of Harrisburg, Pennsylvania

May 17, 2013 SEC Charges City of Harrisburg with Securities Fraud for Fraudulent Public Statements

Pillsbury: Foreign Authorities Are Cracking Down on Corruption

May 14, 2013 Foreign Corrupt Practices Act (FCPA)

Tenaris: SEC's First Use of Deferred Prosecution Agreement

Morrison & Foerster: Deferred Prosecution Agreements Truly a “Game Changer” at the SEC for FCPA Violations?

Cahill: SEC Enters Into First Deferred Prosecution Agreement

Bryan Cave: First-of-its-kind SEC Deferred Prosecution Agreement May Mark a New Era of FCPA Enforcement

SEC Guidance on Enforcement Action Cooperation

Covington & Burling: SEC Doles Out Minimal Benefit to Cooperator

Cozen O'Connor: SEC's First Free Pass Under Cooperation Program...but Don't Expect a Trend

Latham & Watkins: Cooperating with the SEC: Agency Announces First Publicly Disclosed Individual Cooperation Deal

Dodd-Frank Act Enhances SEC's Enforcement Role

Bass Berry Sims: The Expanded Role of SEC Administrative Proceedings Under Dodd-Frank

Stroock: Repeal of Dodd-Frank Confidentiality Protection for SEC: What Investment Advisers Lost and What Remains

Schulte Roth & Zabel: SEC Investigations After Dodd-Frank: A Primer for Hedge Fund Managers and Their In-House Counsel

SEC Actions Dodd-Frank Whistleblowing Rules

WilmerHale: Year Three of the SEC Whistleblower Program: Will It Turbocharge SEC Enforcement?

Latham & Watkins: Attorneys as SEC Whistleblowers: Can an Attorney Blow the Whistle on a Client and Get a Monetary Award?

DLA Piper: Fewer opportunities seen for foreign whistleblowers

Weil: SEC Speaks: Waiting for the New Guard

Sutherland: Summary of Selected Sessions From “The SEC Speaks in 2013”

Drinker Biddle: SEC Speaks 2013: Enforcement Division Highlights Need for Strong Compliance Programs and Continued Efforts to Expand Reach of FCPA Investigations

SEC Investigates "Expert Networks" Re: Insider Trading

Covington & Burling: Expert Networks in the Crosshairs: A Prime Opportunity for Investment Advisers to Bolster Their Insider Trading Compliance Policies and Procedures

Bingham: Massachusetts Secretary of the Commonwealth Proposes New Regulations on Use of Expert Networks and Private Funds Exemption

Cravath: How To Avoid The Pitfalls Of Expert Networking

SEC Launches FCPA Investigation of Financial Advisers & Sovereign Wealth Funds

Latham & Watkins: SEC’s Investigation Request Reveals Scope of Sweep of Advisory Firms Regarding Relationships With Sovereign Wealth Funds

Cadwalader: SEC Launches FCPA Probe of Financial Services Industry's Interactions with Sovereign Wealth Funds

Fulbright & Jaworski: SEC Initiates Investigation of Financial Institutions and Sovereign Wealth Funds for Potential FCPA Violations

SEC's Enforcement Manual

Morrison Foerster: Enforcement Heads Reveal All at SIFMA Annual Seminar

Blank Rome: SEC Investigations Combat Manual

Weil Gotshal; SEC Follows DOJ in Limiting the Use of Waiver of Attorney-Client and Work Product Privileges as a Requirement of Cooperation

SEC's Khuzami on 1st 100 Days and Enforcement Going Forward

Venable: The SEC's New Director of Enforcement Outlines New Initiatives

Bass, Berry & Sims: SEC Enforcement Director Robert Khuzami Speaks: Outlines New Initiatives for the Division of Enforcement

WilmerHale: SEC Director of Enforcement Outlines Significant Changes Signaling Tougher, More Efficient Enforcement Environment

SEC v Black: FD Compliance Pays Off

Winston & Strawn: Companies May Avoid Regulation FD Enforcement Proceedings

Paul Weiss: SEC’s Latest Regulation FD Enforcement Action Highlights the Benefits of a Strong Compliance Program

Mayer Brown: Recent Regulation FD Enforcement and Guidance

SEC Uses S-Ox Clawback Against Uncharged Executive

Jones Day: Court Upholds SEC's Ability to "Claw Back" Millions from Senior Executive Not Charged with Wrongdoing [SEC v. Jenkins]

Fulbright & Jaworski: SEC Claws “Innocent” Officers

DLA Piper: SEC v. Jenkins: no-fault clawbacks for executive compensation take hold

SEC v Rorech & Insider Trading of Derivatives

Proskauer: SEC Jurisdiction Over Credit Default Swaps [SEC v Rorech]

Weil Gotshal: Court Confirms that Insider Trading Laws Apply to Credit Default Swaps [SEC v. Rorech]

DLA Piper: SEC v. Rorech: SEC loses insider trading battle but wins the war on jurisdiction over swaps

In Perry Capital Enforcement Action, SEC Clarifies Rule 13d-1(b) "Ordinary Course" of Business Exception

Winston & Strawn: SEC Charges Investment Adviser With Violations of 13D Filing Requirement [Perry Corp]

Davis Polk: SEC Charges Perry Capital with Disclosure Violations in Connection with Alleged Vote Buying

Weil Gotshal: No “Ordinary Course” For You – The SEC Issues a Warning to Hedge Fund Managers

Hennessee: SEC Slaps Adviser for Poor Diligence

Venable: The Hennessee Aftermath: Lessons to Be Learned from Merkin and Madoff to Avoid Investing in the Next Ponzi Scheme

Sidley Austin: South Cherry Street, LLC v. Hennessee Group LLC, No 07-3658-cv (2d Cir. July 14, 2009)

Goodwin Procter: SEC Settles Enforcement Proceeding with Investment Adviser over Failure to Adhere to Advertised Due Diligence Procedures and Failure to Adequately Investigate “Red Flags” Related to Hedge Fund Recommendations

SEC Enforces Regulation G (Safenet)

Perkins Coie: SEC Settles Its First Regulation G Enforcement Action: How to Avoid Your Own Enforcement Action

Winston & Strawn: SEC Brings First Enforcement Proceeding Under Reg G for Improper Use of Non-GAAP Numbers

Willkie Farr & Gallagher: SEC Brings First Regulation G Enforcement Action