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Cady Bar the Door Insight & Commentary on SEC Enforcement Actions and Related Issues

Monthly Archives: May 2012

SEC Going after Lawyers

Posted in Microcap Fraud

Over the last year, SEC Enforcement Director Rob Khuzami has made no secret of his disdain for defense counsel who engage in “questionable tactics” to gain advantage for their clients involved in SEC investigations.  He made a speech last June in which he cited a number of examples of those tactics.  They included: Multiple representations of… Continue Reading

SEC and DOJ Issue First FCPA Declination Opinions

Posted in FCPA

Some in the FCPA commentariat have long said that the Justice Department and SEC should publicly issue declination opinions when the agencies decide not to pursue a matter.  We already see the factual scenarios that lead those agencies to file charges, in the form of the complaints and indictments themselves.  Many have argued that declination… Continue Reading

Khuzami Touts SEC’s Focus on Compliance

Posted in Compliance, Insider Trading, Investment Advisers, Non-scienter-based Violations

The SEC’s Enforcement Director, Rob Khuzami, gave an interview to Thomson Reuters last week that you should read.  These things are always edited, so it’s hard to know in what order he spoke, but as it is written he gets the interview off to an interesting start.  He does not crow about any particularly “big”… Continue Reading