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Feb 2016

Securities Enforcement 2015 Year-End Review

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The Securities and Exchange Commission (the SEC or the Commission) filed a record 807 enforcement actions in fiscal year 2015, 52 more than it filed in 2014.  It also set a record by obtaining approximately $4.2 billion in disgorgement and penalties in fiscal year 2015, a modest increase over the $4.16 billion it obtained in 2014. 

The second half of 2015 was notable for more than just unprecedented enforcement activity, however.  Some of the key developments over the last six months, which are discussed further in this review, include the departure of Commissioners Luis Aguilar and Daniel Gallagher, challenges to the SEC’s use of administrative proceedings in litigated enforcement actions, the SEC’s continued efforts to secure admissions of wrongdoing as a condition for settling enforcement actions, the grant of a conditional bad-actor waiver to a large financial institution, the ever-increasing use of the Commission’s Whistleblower Program, a series of enforcement actions arising out of the SEC’s review of cybersecurity systems, the impact of the Supreme Court’s grant of certiorari in United States v. Salman on the future of insider trading, the institution of enforcement actions against compliance personnel, and the Second Circuit’s long-awaited decision in United States v. Litvak on what statements can qualify as material in securities fraud actions.

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