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Jul 2016

Securities Enforcement: 2016 Mid-Year Review

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The Securities and Exchange Commission instituted over 400 enforcement actions in the first half of 2016 and is on pace to surpass its record of 807 enforcements actions in a single fiscal year, which it set last year. In our 2016 mid-year review, we examine key developments in the SEC’s enforcement program through June 2016, and how those developments will shape the rest of 2016, including:

  • fairness and constitutionality of the SEC’s use of administrative proceedings;
  • continuing debate on cooperation credit;
  • enforcement actions against compliance professionals;
  • SEC’s ability to obtain disgorgement for long past conduct;
  • whistleblower program;
  • SEC’s requirement that defendants admit wrongdoing as a condition of settlements;
  • enforcement actions involving insider trading; and
  • enforcement actions involving the Foreign Corrupt Practices Act, private equity and investment advisers, cybersecurity, accounting and financial disclosures, and broker-dealers

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