Category: SEC enforcement
Remaining Vigilant to Compliance and Enforcement Concerns in Times of Crisis
In times of increased financial stress—and particularly during times of financial shock where expectations and reality diverge significantly and rapidly—internal and external pressures can lead to risk-taking with lasting consequences. For example, pressure often mounts to boost revenue to save a failing quarter, to take advantage of government bailout opportunities, […]
US v. Connolly: District Court Scrutinizes Longtime Corporate Practices for Internal Investigations
“On May 2, 2019, the chief judge for the Southern District of New York, the Honorable Colleen McMahon, issued a decision that pointedly criticized certain long-standing practices by which corporations conduct – and the government directs – internal corporate investigations. In United States v. Connolly, No. 16-cr-0370 (S.D.N.Y. May 2, 2019), […]