Pre-existing, Substantive Relationships and General Solicitation

As cryptocurrency issuance declines, the Securities and Exchange Commission is continuing to clean out the fraud, mis-steps, and foolishness of coin promoters. These actions have carried over to the services and investment managers involved in coin offerings. Usman Majeed wanted to make his money by running a fund that invests in cryptocurrency. He ran into … Read more »

Compliance Bricks and Mortar for March 29

These are some of the compliance-related stories that recently caught my attention. Conflicts of interest for “the little people”by Jeff KaplanConflicts of Interest Blog The conclusion of the Mueller investigation does little to resolve the much broader set of concerns regarding President Trump’s conflicts of interest. These are too numerous to be chronicled on this … Read more »

Compliance, the SEC and the Supreme Court

SEC Wins at SCOTUS

Can the Securities and Exchange Commission penalize an investment banker even though he did not “make” false statements? The SEC is claiming that his distribution of those false statements constituted a “device, scheme, or artifice to defraud” or an “act, practice, or course of business which operates . . . as a fraud or deceit” … Read more »

The Continued Rise of Professional Whistleblowing

The Securities and Exchange Commission announced awards totalling $50 million to whistleblowers who brought high-quality information to the SEC and assisted in bringing a successful enforcement action. As with all whistleblower awards, the order is heavily redacted as to the company involved, what happened, and when it happened. I’m not sure I can identify which … Read more »