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Cady Bar the Door Insight & Commentary on SEC Enforcement Actions and White Collar Crime

Monthly Archives: May 2012

Will Raj Rajaratnam Testify against Rajat Gupta?

Posted in Cooperation, Insider Trading, Sentencing

Rajat Gupta’s insider trading trial is proceeding apace in the Southern District of New York.  While there have certainly been enough entertaining witnesses to keep close observers busy so far, none would be as Earth-shaking as news of Raj Rajaratnam’s testimony.  As you know if you’re reading this post, Rajaratnam was convicted in the same… Continue Reading

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