Month: October 2020

The access or gatekeeper theory of enforcement traces to the early days of the Division of Enforcement, launched in 1972. The idea was to leverage the scarce resources of the Division and the agency to create a more effective enforcement …

The Access Theory: A Key Enforcement Approach Read More »

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The Commission filed actions this week focused on stock repurchases and the FCPA. The former charged firm for failing to have proper compliance procedures tied to its repurchase program. The latter centered on a Brazilian corruption scheme. While the Order …

This Week In Securities Litigation (Week of October 19, 2020) Read More »