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Sep 29, 2014

Broken Windows: SEC Enforcement Reminds Officers, Directors and 5% Shareholders to Comply with Reporting Requirements

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On September 10, 2014, the United States Securities and Exchange Commission (the “SEC”) announced enforcement proceedings against officers, directors and major shareholders and publicly-traded companies for violations related to beneficial ownership filings. The broader lesson of these enforcement actions is that, consistent with Chair White’s “broken windows” enforcement philosophy, the SEC’s threshold for pursuing violations of the securities laws has been lowered. Publicly-traded companies, regulated entities and all those that are subject to the federal securities laws should ensure that they have robust policies and procedures in place to ensure compliance with all applicable reporting requirements.

View full memo, Broken Windows: SEC Enforcement Reminds Officers, Directors and 5% Shareholders to Comply with Reporting Requirements

Authors and Contributors

Matthew Bersani

Partner

Capital Markets

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+852 2978 8096

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David Dixter

Partner

Capital Markets

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London

Stephen T. Giove

Partner

Capital Markets

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New York

Masahisa Ikeda

Partner

Capital Markets

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+81 3 5251 1601

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Tokyo

Lisa Jacobs

Partner

Capital Markets

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New York

Jason Lehner

Partner

Capital Markets

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Toronto

Sami Toutounji

Partner

Compensation, Governance & ERISA

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Paris