On June 4, 2014, after two-and-a-half years, the U.S. Court of Appeals for the Second Circuit finally ruled in favor of the SEC in its high-profile appeal involving a proposed settlement with Citigroup Global Markets. As discussed here in detail, the SEC’s appeal followed U.S. District Judge Jed Rakoff’s November 2011 order in which he […]
Bruce Carton
SEC Awards $400,000 to Whistleblower After Company Fails to Address Internal Reports of Fraud
Today, the SEC announced a whistleblower award that may, for two reasons, resonate with potential tipsters and companies that might be reluctant to take decisive action to look into fraud that is reported internally. First, the SEC’s award, which it issued to an unidentified whistleblower, was for the not-insignificant amount of $400,000. Second, the […]
Report Stacks Up Top-Producing Plaintiffs Securities Class Action Law Firms for 2013
For over a decade now, ISS’ Securities Class Action Services has released its annual “Securities Class Action Services 50” — a list of the top 50 law firms based on the total settlement amounts each law firm produced for investors in the calendar year. Specifically, the SCAS 50 for 2013 ranks the law firms based on […]
FOIA Response Sheds Light on Backgrounds of SEC Whistleblowers
Since mid-2011, the SEC’s Office of the Whistleblower has been taking in tips about alleged securities fraud. Via a recent request made under the Freedom of Information Act, the WSJ set out to answer an interesting question: from what fields and professions do these whistleblowers come from? Based on the 3,600 whistleblowers to date who listed […]
House Bill Slashes $300 Million from Pres. Obama’s Proposed SEC Budget
Back in March 2014, President Barack Obama proposed a fiscal year 2015 budget of $1.7 billion for the Securities and Exchange Commission–a 26% increase over the agency’s FY 2014 budget. SEC Chair White testified shortly thereafter before a subcommittee of the House Committee on Appropriations that after receiving just a 2% budget increase in FY […]
People Who Don’t Get It: Investor Relations Execs Who Engage in Insider Trading
Not too far removed from public company employees who foolishly believe they can get away with insider trading in their own company’s stock are investment relations executives who foolishly think they can get away with insider trading stock in the stock of their public company clients. Bad idea! The latest example from the investment relations […]
Insider Trading Defendant Tries Out ‘Notorious B.I.G.’ Strategy at Sentencing
Former investment banker Frank Perkins Hixon Jr. tried out a different approach in court yesterday when he argued that the court should sentence him to a prison term of less than four years. Let’s call it the “Notorious B.I.G.” strategy. You may recall that rap legend Notorious B.I.G. introduced himself to the world in 1994 […]
Why SEC and DOJ are on Different Playing Fields for FCPA Enforcement
Over at the FCPA Professor blog, which celebrated its 5th birthday this week, Professor Mike Koehler offers an important reminder to those who would compare the SEC’s enforcement in the FCPA area to that of the DOJ. Kohler’s post was prompted by a Wall Street Journal Risk & Compliance Journal article last week (“SEC Stays […]
‘Laws of the Land’ Finally Catching Up to Former Satyam CEO
In January 2009, B. Ramalinga Raju, chairman and CEO of Satyam Computer Services, an Indian company, stunned India and the company’s shareholders when he admitted in a letter to the board of Satyam that he had falsified the company’s financial records in a $1 billion fraud. In the letter, Raju resigned and agreed to “subject myself to the laws […]
Gamification Spreads to Investment Banking with ‘The M&A Game’
Back in August 2013 I wrote about the “gamification” of compliance training after True Office announced the release of an anti-insider trading game that uses the scenario of a fictional investment bank that is accused of insider trading. But why stop there? As of this week, investment banking itself has been gamified with the release (via FT Alphaville) by a […]


