This Week In Securities Litigation (Week of January 20, 2025)
This Week In Securities Litigation (Week of January 20, 2025)
Over the last week the Commission filed a variety of cases. Those included insider trading, offering fraud actions, sham transactions, false statements, unregistered broker cases, misappropriation, improper accounting, ineffective controls, crypto assets and binary options.
Be careful, be safe this week and be warm
SEC Enforcement – Filed and Settled Actions
Statistics: Last week the Commission filed 10 new civil injunctive actions and 9 new administrative proceedings.
Offering fraud: SEC v. Nova Labs, Inc., Civil Action No. 1:25-cv-00539 (Jan. 17, 2025) is an action which names as defendant Nova Labs, Inc. The complaint alleges that Defendant marketed unregistered investment contracts and made false statements in connection with its sales of investment contracts. Since April 2019 Defendant has raised millions of dollars through the sale of investment contracts marketed in connection with the firm work. This was through the sale of what Defendant called Hotspots – electronic devices that supposedly mined one of three Nova Labs crypto assets. The firm also told potential investors that three large, well known firms would aid in creating demand for its product. In fact, the firms identified were not using the products – the claims were false. The complaint alleges violations of Securities Act Sections 5(a) and 5(c) and Exchange Act Section 10(b). See Lit. Rel. No. 26229 (Jan. 18, 2025).
Sham transactions/selling away: SEC v. Arete Wealth Management, LLC, Civil Action No. 1:250-cv-00616 (N.D. Ill. Filed January 17, 2025). Named as defendants in this action are the firm, a registered broker; Arete Wealth Advisors, LLC, a registered investment adviser; Joey Miller; Jeffrey Larson; Randal Larson and Unbo Chung. Defendants Miller, Jeff Larson and Randy Larson are sales representatives at Defendant Arete Wealth Commission Representatives and sales representative at Defendant Arete Wealth. In late 2018 and early 2019 Defendants Miller and Jeff Larson agreed with Richard Sterritt (a/k/a Richard Richman) to raise money for Zona from investors in exchange for discounted shares of the firm. Randy Larson joined this effort. The deal was not disclosed to customers or the firm. In January 2020 the Arete Representative and Mr. Chung received an anonymous email claiming that Richard Richman was actually Richard Sterritt, a convicted felon. Nevertheless, in early 2020 some of the Arete Representatives invested additional funds in Zona with the assistance of the Arete Representative. By late Spring about $8.5 million was invested in Zona – about half the amount raised from investors. In April 2021 the U.S. Attorney’s Office for the Eastern District of New York and the Commission respectively, filed criminal and civil charges against Defendant Sterritt and others claiming that Zona was a sham entity and that the Sterritt and other Zona insiders had misappropriated investor funds. FINRA also began an investigation. Compliance requirements were ignored as these transactions unfolded. Ultimately the Arete Representatives’ customers and other investors lost all of their funds. The complaint alleges violations of Securities Act Section 17(a), Exchange Act Section 10(b) and Advisers Act Sections 206(1), (2) and (4). See Lit. Rel. No. 26228 (Jan. 17, 2025).
False statements: SEC v. Sanaullah, Civil Action No. 2:25-cv-10165 (E.D. Mich. Filed Jan. 16, 2025). Naufal Sanaullah, the chief risk officer of EIA All Weather Alpha Fund I Partners. Over a period of about three years, beginning in late 2017, he solicited Fund investors and prospective investors to invest in the fund using a series of false statements regarding the safety and operations of the Fund. The complaint alleges violations of Securities Act Section 17(a) and Exchange Act Section 10(b). The Commission previously filed a complaint against the firm and its CEO, Andrew M. Middlebrooks based on similar charges. See Lit. Rel. No. 26227 (Jan. 17, 2025).
Unregistered brokers: SEC v. Quest Education LLC, Civil Action No. 2:25-cv-00105 (D. Nev. Filed Jan. 17, 2025) is an action which names as defendants: the firm; David Christopher White, its principal; and Keith Jordan Spears, an employee. Over about a three-year period, beginning in April 2023, the firm raised over half of its revenue by acting as an unregistered broker. Quest was typically paid up to about 7% of the amount invested in the firm by an investor. The individual Defendants typically vouched for the firm when soliciting investors. Indeed, the individual Defendants typically were paid up to 1% for successful solicitations over a period that began in October 2019 and continued for about four years. The complaint alleges violations of Securities Act Sections 5(a), 5(c) and Exchange Act Section 15(a)(1). See Lit. Rel. No. 26226 (Jan. 17, 2025). See Lit. Rel. No. 26226 (Jan. 17, 2025).
Offering fraud: SEC v. American Equities, Inc., No. 3:22cv-621 (D. Or.) is a previously filed action which named as defendants the firm, American Eagle Mortgage Management LLC, Ross Miles, and Maureen Wile. Previously, each Defendant consented to the entry of final judgments; individual defendants Miles and Wile also consented to the entry of officer/director bars. The complaint charges Defendants with defrauding investors for over a decade. It alleged violations of Securities Act Section 17(a) and Exchange Act Section 10(b) which were the Sections included in the initial settlement. The final judgment, entered on January 15, 2025, also directed the payment of disgorgement, prejudgment interest and a civil penalty on a joint and several basis. The disgorgement order was $1,146,307.10, prejudgment interest was also included in the amount of $230,464 along with a penalty of $230,484. See Lit. Rel. No. 26225 (Jan. 17, 2025).
Misappropriation: SEC v. Mason, Civil Action No, 2:25-cv-00292 (E.D. Pa. Filed Jan. 17, 2025) is an action which named as defendants Scott Mason, Rubicon Wealth Management, LLC and Orchard Park Real Estate Holdings LLC. Mr. Mason controlled the two entities. The complaint alleges that former registered investment adviser Rubicon, along with Defendant Orchard Park, defrauded at least 13 Rubicon clients over a four-year period, beginning in 2016. Mr. Mason, according to the complaint, provided concierge services to one client and abused access to the client’s accounts by transferring millions of dollars from the client account to ones he controlled. During the period 2014 to 2024 about $20 million in clients funds were transferred as part of the scheme prior to its end. The complaint alleges violations of Exchange Act Section 10(b) and advisers Act Sections 206(1) and 206(2). A parallel action was filed by the U.S. Attorney’s Office for the Eastern District of Pennsylvania. See Lit. Rel. No. 26224 (Jan. 17, 2025).
Independence: In the Matter of Jeffery Q. Johnson, Adm. Proc. File No. 3-22432 (Jan. 17, 2025) is a proceeding which name as Respondent a CPA who is a partner with Forvis Mazars, LLP. Respondent served as engagement partner at BKD, LLP. Respondent violated the Regulation S-X independence requirement when he audited private fund financial statements that he had prepared. Respondent also violated an earlier Commission order that denied him the privilege of appearing and practicing before the Commission as an auditor by signing two consents allowing audit reports he has signed for a private company to be included in registration statements filed with the agency. Respondent also violated the custody rule by auditing financial statements for which he conducted audits – the custody rule requires the auditor to be independent. Respondent caused the Adviser to violate Advisers Act Section 206(4) and Rule 206(4)-2. The Commission concluded that Respondent engaged in improper professional conduct under Rule 102(e)(ii). As a result, Respondent Johnson is ordered to cease-and-desist from committing or causing any further violations of Advisers Act Section 206(4) and Rule 206(4)-2. He is also denied the privilege of appearing and practicing before the Commission as an accountant. Respondent was, in addition, directed to pay a penalty of $30,000. See also In the Matter of Jeffery Q. Johnson, CPA, Admin. Proc. Order File No. 3-22432 (Jan. 17, 2025)(engagement partner at BKD not independent re audits of financial statements of private fund where he prepared financial statements; resolved with same sanctions as case above).
Improper accounting: In the Matter of Celsius Holdings, Inc., Adm. Proc. File No. 3-22429 (Jan. 17, 2025) is a proceeding which named as Respondent Celsius Holdings, a firm that sells fitness drinks, and is alleged to have engaged in improper accounting. Specifically, in 2021 the firm improperly accounted for stock-based compensation expenses by modifying the term of stock awards for six departing employees and board members when noting the arrangements in filings. The firm also failed to have in place disclosure controls designed to ensure the financial information was properly booked. The Order alleges violations of Exchange Act Sections 13(a), and 13(b)(2)(A), and the related rules. The proceedings were resolved with the entry of a cease-and-desist order based on the Sections cited in the Order and the related rules and the payment of a $3 million penalty
Ineffective internal controls: In the Matter of Singularity Future Technology, Ltd., Adm. Proc. File No. 3-22424 (Jan. 17, 2025) names as Respondent the shipping and logistics company that operates through a number of subsidiaries located in China and Hong Kong. For the last eight fiscal years the firm has reported that its internal controls as to financial reporting has been ineffective. The Order alleges violations of Exchange Act Section 13(a), 13(b)(2)(A) and 13(b)(2)(B). The firm has also undertaken to fully remediate is control issues. To resolve the proceedings the firm will complete its undertakings, consented to the entry of a cease-and-desist order based on the Sections cited and the related rules and will pay a penalty of $350,000.
Financial controls: In the Matter of American Electric Power Company, Inc., Adm. Proc. File No. 3-22425 (Jan. 17, 2025). These proceedings arise out of the electric power firm’s relationship with Larry Householder (former Speaker of the House for the Ohio House of Representatives) and Generation Now Inc., a 501(c)(4) organization controlled by Rep. Householder. Both were charged with federal racketeering and conspiracy based on a years long scheme. Following the charges Respondent issued statements noting that it did not make any contributions to Generation Now. The firm failed to disclose material related party transactions with respect to payments it made to Empowering Ohio in 2019 and to keep accurate books and records. In resolving the matter Respondent agreed to undertaking certain matters and consented to the entry of a cease-and-desist order from causing any violations of Securities Act Section 17(a)(2) and Exchange Act Sections 13(a), 13(b)(2)(A) and 13(b)(2)(B). The firm will also pay a penalty of $19 million.
Unregistered offers/sales: In the Matter of Investview, Inc., Adm. Proc. File No. 3-22423 (Jan. 17, 2025) is a proceeding in which the firm engaged in the unregistered offer and sale of securities from July 2019 through June 2020. The transaction centered on the sale of securities in the form of interests in a sale/leaseback program called Apex Program. There was no registration statement or exemption. The Order alleges violations of Securities Act Sections 5(a) and 5(c). To resolve the matter the firm consented to the entry of a cease-and-desist order based on Securities Act Sections 5(a) and 5(c). In addition, Respondent will pay a penalty of $375,000.
Undisclosed conflicts: In the Matter of Transamerica Retirement Advisors, LLC, Adm. Proc. File No. 3-22426 (Jan. 17, 2025) is a proceeding in which the registered investment adviser breached its fiduciary to certain advisory clients by failing to disclose conflicts created by paying incentive compensation to its investment advisor representative in connection with the rolling over of retirement in connection with recordkeeping services provided to these plans by an affiliate of the advisor. Before 2017 the firm disclosed that it “may” make such payments which is inadequate disclosure. By February the firm actually disclosed the practice. The Order alleges violations of Advisers Act 206(2) and 206(4). Respondent consented to the entry of a cease-and-desist order based on the Section cited in the Order. The firm also agreed to pay a penalty of $2.9 million and to the entry of a censure.
Crypto assets/ rug pull: SEC v. Zhu, Civil Action No. 3:25-cv-00054 (M.D.L.A. Filed Jan. 16, 2025). Defendant Eric Zhu is a freelance blockchain engineer residing in New York. He was retained to provide technical assistance in connection with a new crypto asset known as GME. Game Coin, LLC, is a Louisiana based firm formed in August 2021 for the purpose of developing a website-based marketplace that would permit amateur athletes to create digital trading cards. Individual 1 and Individual 2 worked largely in the landscaping business. From June 2021 through September of the same year Defendant Eric Zhu participated in the creation of a new game token that would be offered and sold as a crypto asset security to investors. Individual 1 and 2 had contemplated the creation of a new crypto asset that was designed to serve as a medium of exchange for digital trading cards available for sale on the marketplace. The new asset, called GME, was promoted on social media. Investors were promised that a marketplace would be built so they could use GME to buy digital trading cards of amateur athletes. Mr. Zhu, an experienced blockchain engineer, was retained to perform coding work for the offer and sale of GME to the public. Over a period of several months, beginning in June 2021, Individual 1 and Individual 2 sold GME to investors through a crypto asset trading platform known as PancakeSwap. The firm facilitated the transactions through the creation of what were called liquidity pools – pools of assets that could be exchanged for each other. In June 2021 Individual 1 and Individual 2 launched the public sale of GME by establishing a PancakeSwap liquidity pool that enabled investors to buy and sell GME. They also arranged for a crypto asset known as Binance Coin or BNB, to serve as the initial liquidity for the GME Liquidity Pool. Investors could interact with GME Liquidity Pool, buying GME and depositing BNB or selling GME and withdrawing BNB. A person who deposited a crypto asset token pair into the Liquidity Pool received a “liquidity provider” token or LP token. Those tokens had risk, however, since the LP token holder could sell off large volumes of them. Individual 1 and Individual 2, in view of the risks, represented in social media posts that there were safeguards such that liquidity was locked – the LP tokens could not be used by issuers or insiders to withdraw liquidity in a rug pull-like fashion. Mr. Zhu was aware of the risks. He kept LP tokens unlocked, something that was not known to others. He then withdrew GME and BNB from the Liquidity Pool. Mr. Zhu used the unlocked LP tokens to withdraw GME and misappropriate crypto assets worth about $553,000 – essentially, he did what traders call a rug pull. The value of the assets declined in price by 12%. The Commission’s complaint alleged violations of Securities Act Sections 17(a)(1) and 17(a)(3) as well as Exchange Act Section 10(b) and Rule 10b-5. Mr. Zhu resolved the matter by consenting to the entry of permanent injunctions based on the Sections cited in the complaint. He also agreed to pay disgorgement and prejudgment interest of $672,992 and a civil penalty of $150,000. See Lit. Rel. No. 26223 (Jan. 16, 2025).
Unregistered sales: SEC v. Gogioere, Civil Action No. 18-cv-1530 (S.D. Cal.) is a previously filed action in which the Commission obtained a grant of summary judgment. The order was against Andrew Hadckett and based on his criminal conviction is a related case. The action alleged was based on the sale of unregistered shares of Arias Intel Corp. Beginning in August 2017 Defendant purchased shares of ASNT. This activity was to continue until the share price hit the target price of $5 per share. As the shares were sold, some were purchased by an undercover FBI agent. The court concluded in its ruling on the summary judgment motion that there were violations of Exchange Act Section 10(b) and Rule 10b-5. The amount of disgorgement ordered is satisfied by the order of restitution in the criminal case. The injunction also contains a penny stock bar. See Lit. Rel. No. 26222 (Jan. 16, 2025).
Unregistered sales. SEC v. Plutus Lending, LLC, Civil Action No. 1:24-cv-02457 (D.D.C.) is a previously filed action in which a final judgment was entered. The judgment ordered the firm to pay a civil penalty of $1,650,000. It included a permanent injunction based on Securities Act Sections 5(a) and 5(c) and Investment Company Act Section 7(b). The complaint alleged the sale of unregistered securities. See Lit. Rel. No. 26220 ((Jan. 15, 2025).
Failure to file: SEC v. Musk, Civil Action No. 25-cv-105 (D.D.C. Filed January 14, 2025). Elon Muck began in March 2022 purchasing shares of Twitter common stock. By March 14, 2022, he had acquired beneficial ownership of over 5% of the firm’s outstanding common shares. During the period, Exchange Act Section 13d-1 required Mr. Musk to file with the Commission a beneficial ownership report disclosing his transaction within ten calendar days after crossing the 5% level. He did not. By not filing Mr. Musk saved over $150 million, according to the Commission. Mr. Musk’s gains were the losses for other traders in the market as he traded. On April 4, 2022, Mr. Musk publicly disclosed his beneficial ownership in a report filed with the Commission. The filing disclosed that he had acquired over 9% of the shares. Following the announcement the share price increased by over 27% over the prior day’s close. By not complying with Section 13(d) Mr. Musk saved over $150 million. He spent over $500 million to acquire the block of stock. The complaint alleges violations of Exchange Act Section 13(d). See Lit. Rel. No. 26219 (January 14, 2025).
Insider trading: SEC v. Tobia, Jr., Civil Action No. 1:25-cv-00280 (S.D.N.Y. Filed Jan. 13, 2025) is an action which names as defendants Alfred Tobia and Elizabeth Lee, respectively, the former chief financial officer and member of the board of another company, and Mr. Tobia’s sister-in-law, Elizabeth Lee, with insider trading. Defendant Tobia is alleged to have breached his fiduciary duty as president and CIO of the public company by tipping Ms. Lee about his company plan to make an offer to acquire all the shares of Spok Holdings Inc. When the deal press release was issued Ms. Lee sold all her shares of Spok, resulting in profits of over $262,000. In addition, while serving as a member of the board of the other public company, Mr. Tobia learned inside information about PFSWeb.Inc.’s sale of one of its business units and tipped the information to Ms. Lee who traded. She had profits of over $166,000. Each Defendant has agreed to resolve the charges by consenting to the entry of permanent injunctions. The complaint alleges violations of Exchange Act Section 10(b). Mr. Tobia also agreed to the entry an officer/director bar for five-years and to pay a penalty of $785,020. Ms. Lee agreed to pay a penalty of $576,955. See Lit. Rel. No. 26218 (Jan. 13, 2025).
False statements: SEC v. Joecool.com, LLC, Civil Action No. Civil Action No. 2:25-cv-00076 (D.Nev. Filed Jan. 14, 2025) is an action which names as defendants: the company, a firm which purported to offer various CBD-infused coffee products; Joseph Haber, controller of the company; and Robert Cournoyer, v.p. of investor of public relations. The firm raised at least $2 million from investors based on claims it would market cannabidiol infused coffee products. Yet about half of the funds raised went to Mr. Haber’s gambling while other funds were diverted to other matters. The complaint alleges violations of Securities Act Sections 5(a), 5(c) and each subdivision of Section 17(a) and Exchange Act Section 10(b). See Lit. Rel. No. 26216 (Jan. 14, 2024).
Cybersecurity: SEC v. Ashford, Inc., Civil Action No. 3:25-cv-00082 (N.D. Tex. Filed 1/13/25). Ashford, a public company, provides product and services to the real estate and hospitality industries. In September 2023 the firm learned that it had been subjected to a cybersecurity attack and ransomware demand by a foreign-based threat actor. The threat actor gained access to the firm and exfiltrated about 12 terabytes of data stored on its internal systems. As required, Ashford disclosed the incident after it was identified. In September 2023 the firm disclosed in a Form 10-Q that it had experienced a Cyber Incident. The filing stated that the firm had completed an investigation and identified “certain employee information that may have been exposed. . .” The report went on to state that the company “had not identified that any customer information was exposed.” Similar disclosures were made in two subsequent filings. Ashford knew that contrary to its disclosures, customer information was exposed – the files exposed to the incident contained customer information. It included sensitive personally identifiable information for some customers, according to documents produced by the company to the Commission during its investigation. The inaccurate disclosures violated Securities Act Sections 17(a)(3) and Exchange Act Section 13(a) as well as Rules 12b-20, 13a-1 and 13a-13. To resolve the matter, the company consented to the entry of a permanent injunction based on the Sections cited. The firm also paid a civil penalty of $115,231 which took into account the cooperation of the company with the Commission’s investigation.
Offering fraud: SEC v. Ichioka, Civil Action No. 3:23-cv-03093 (N.D. Cal.) is a previously filed action in which Defendant William K. Ichioka is alleged to have conducted a fraudulent offering through his investment fund, Ichioka Ventures. The complaint alleges Defendant falsified his background and made Ponzi type payments to investors. Defendant resolved the matter by agreeing to the entry of a permanent injunction based on Exchange Act Section 10(b), Securities Act Section 17(a) and Advisers Act Sections 206(1) and 206(2). Defendant will also pay disgorgement of $30,994,308.97 and prejudgment interest of $336,406.89. Those amounts are satisfied by the order of restitution entered in the parallel criminal action. See Lit. Rel. No. 26214 (Jan. 13, 2025).
Insider trading: SEC v. Sure, Civil Action No. 4:22-cv-01967 (N.D. Cal.) is a previously filed action which names as defendants Hari Prasad Sure, Lokesh Lagudu, Chotu Prabhu Tej Pulagam, Dileep Kumar Reddy Kamujula, Sai Mounika Nekkalapudi, Avhishek Dhamapurika and Chetan Prabhu Sree Karteek Pulagam, The complaint claims that Defendants Sure, Laguda, and Chotu Pulagam, all software engineers employed at Twilio, Inc., a San Francisco based cloud computing company, engaged in insider trading in advance of Twilio’s positive first quarter 2020. Four of their family members and friends engaged in insider trading. The insider defendants knowingly tipped Kamujula, Nekkalapudi, Dharmapurikar, and Chetan Pulagam to trade. Seven defendants were charged with violations of Exchange Act Section 10(b). Defendants Sure and Kamujula previously plead guilty in the parallel criminal action filed by the U.S. Attorney’s Office for the Northern District of California, U.S. v. Shure, No. 4:23-cr-00254 and U.S. v. Kamujula, No. 4:22-cr-00131. See Lit. Rel. No. 26217 (Jan. 14, 2025).
Disclosure: In the Matter of Shift4 Payments, Inc. Adm. Proc. File No. 3-22393 (Jan. 10, 2025) is a proceeding in which the firm failed to disclose related person transactions in its annual reports and definitive proxy statements. The Order alleges violations of Exchange Act Section 13(a) and the related rules. The proceedings were resolved with remedial efforts, a consent to the entry of a cease-and-desist order based on Exchange Act Sections 13(a) and 14(a) and the related rules. Respondent also agreed to pay a penalty of $750,000.
Disclosure: In the Matter of One Thousand & One Voices Management, LLC, Adm. Proc. File No. 3-22392 (Jan. 10, 2025) is a proceeding which names a respondents: the firm listed in the caption, a registered investment adviser; Family Legacy Capital Credit Management, LLC, a firm that withdrew its registration as an adviser; and Hendrik Jordaan, the sole owner of the Fund Managers. Here certain expenses were improperly charged to the Private Funds and not disclosed. The governing documents for the Private Funds did not permit the payment of such expenses. The Order alleges violations of Advisers Act Sections 206(2) and 204(4). To resolve the proceedings Respondents consented to the entry of cease-and-desist orders based on the Section cited above and the related rules. One Thousand and One Voices and Respondent Jordaan also agreed to pay, on a joint and several basis, disgorgement of $1,522,572 and prejudgment interest of $272,222. That amount is deemed satisfied by the elimination of an accrual. In addition, One Thousand and Once Voices Manager and Respondent Jordaan shall pay, jointly and severally, a penalty of $150,0000.
Binary options: In the Matter of Jonathan Mimun, Adm. Proc. File No. 3-22390 (Jan. 10, 2025) is a proceeding with names as respondents Mr. Mimun and Ronn Ben Harav. Over a three-year period, beginning in 2014, Respondents offered and sold binary options across the U.S. To do this Respondents used various names. Respondents sold the options through a call center. While customers were assured of the expertise of Respondents, in fact they made money through the losses on the transactions. The Order alleges violations of Securities Act Section 17(a) and Exchange Act Section 10(b). In April 2024 a judgment was entered against Respondents which found them jointly and severally liable for disgorgement of about $25.7 million, prejudgment interest of about $7.3 million and found each Respondent individually liable for a penalty of about $12.8 million. The judgment also enjoins Respondents from future violations of Securities Act Section 17(a) and Exchange Act Section 10(b) and 15(a). The judgment prohibits, in addition, certain future conduct with respect of the sale of binary options and certain other securities over the internet. The Commission determined it appropriate to institute certain proceedings that will provide Respondents a hearing and provide for the taking of evidence.
FinCEN
Summit: The agency convened a “virtual summit” of financial intelligence units to combat “nature crimes” in the Amazon Region, according to an article published by the regulator on January 17, 2025 (here).
ESMA
Report: ESMA published its seventh market report on the cost and performance of EU retail investment products. This report, like earlier ones, shows a decline in the cost of investing in key retail investment products. Nevertheless, the regular notes that “the cost levels of funds in the EU remains high by international standards” (here). The report goes on to note that EU funds do not exhaust the economies of scale commensurate with the EU’s single market. The market inefficiencies revealed by the higher cost level shows the need to focus on the competitiveness of EU markets, within a future Savings and Investments Union,” according to the January 1, 2025 report (here).
Hong Kong
Remarks: Dr. Kelvin Wong, Keynote speaker at the Association of Hong Kong Capital Market Practitioners’ Seminar delivered remarks titled “Enhancing Sponsors’ Value Proposition to Drive GEM Advancement” at the Association of Hong Kong Capital Market Practitioners Seminar on January 17, 2025 (here).
Singapore
Paper: The Monetary Authority of Singapore published a Consultation Paper on Proposed Revisions to Enterprise Risk Management, Investment and Public Disclosure Requirements for Insurers” on December 20 2024 (here).