This perhaps goes without saying, but when the SEC’s enforcement staff call to ask about potential securities law violations, they aren’t just gathering facts, as they like to say. And it can be very hard to know what to do in response. Kenneth Wrangell got such a call recently, and it appears that he made… Continue Reading
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Will Raj Rajaratnam Testify against Rajat Gupta?
Posted in Cooperation, Insider TradingRajat 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’s Individual Cooperation Program Gets off the Ground
Posted in Accounting Fraud, CooperationAt times, the SEC staff is confronted with investigations in which an individual seems likely to have quite a bit of information about the investigation’s core matters but little or no responsibility for any misconduct. Not so long ago, when trying to collect information from those people, the staff really had only one option: subpoena… Continue Reading