Year: 2018

Exchange Act section 13(b)(2)(B), added to the 1934 Act as part of the Foreign Corrupt Practices Act of 1977, is concerned with internal accounting controls. The statute requires that there be sufficient controls to ensure that transactions are executed as …

The SEC, Internal Accounting Controls and the Human Element Read More »

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During the week leading up to the Thanksgiving holiday, and the day after, the Commission filed two actions centered on initial coin offerings. Those actions, involving coin offerings that follow the issuance of the DAO section 21(a) report, set a …

This Week In Securities Litigation (Week ending Nov. 23, 2018) Read More »

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