On April 12, the U.S. Senate quietly passed a bill that gutted part of the STOCK Act, a law passed with much fanfare last year that is supposed to create transparency around stock trading by members of Congress and their employees on material, non-public information. On April 15, President Obama just as quietly signed that bill into law, […]
Bruce Carton
SEC Enters First-Ever Non-Prosecution Agreement in FCPA Case
Yesterday the SEC announced a non-prosecution agreement (NPA) with Ralph Lauren Corporation related to alleged bribes a subsidiary of the company paid to government officials in Argentina from 2005 to 2009. The agency noted in a press release that the NPA with Ralph Lauren Corp. was the first that the SEC had entered involving Foreign Corrupt Practices […]
SEC Names George Canellos and Andrew Ceresney Co-Directors of Enforcement Division
Today, the SEC announced that Acting Director of Enforcement George Canellos and Andrew Ceresney have been named Co-Directors of the Division of Enforcement. As discussed here previously, Ceresney is a partner at law firm Debevoise & Plimpton, and he worked with new chairman Mary Jo White while at that firm and also while he was a federal […]
Web Watch: Best of the Week Ending April 19
Throughout the week over at Securities Docket I highlight the most interesting columns and blog posts from around the web on the subjects of SEC enforcement and securities litigation. Here is a digest of my picks for the week ending April 19. The FCPA’s Back, Baby! Samuel Rubenfeld, WSJ Risk & Compliance The U.S. Justice Department and Securities […]
Chairman White Reportedly Set On Ceresney as Next Enforcement Director
It is still not official, but Reuters is now reporting that Andrew Ceresney, said for over a month to be the leading candidate to follow Robert Khuzami as the SEC’s next Director of Enforcement, will in fact be named to that post by Chairman Mary Jo White in the “coming weeks.” Reuters reports that Ceresney has “already […]
Documentary Promises ‘New and Shocking’ Look at Madoff Scandal
The Tribeca Film Festival kicks off in New York City today. Usually film festivals are beyond the scope of the Enforcement Action blog, but this year the festival includes an interesting-looking documentary called “In God We Trust” about the Bernard Madoff scandal. According to the festival’s synopses, In God We Trust tells the Madoff story from the […]
Rogue Broker’s ‘Brazen, Ill-Conceived Scheme’ Brings Down Conn. Brokerage Firm
The SEC alleges that on October 25, 2012, a registered representative named David Miller came to work at Rochdale Securities LLC and, by the end of the day, had taken the entire firm down through a very misguided scheme. The SEC alleges that Miller engaged in a series of “rogue” trades in Apple stock on the day that […]
Before You Accept that Envelope Full of Cash In Exchange for Inside Info…
Before you accept that envelope stuffed with cash in exchange for inside information about public companies, just remember that sometimes it is a set-up. And the FBI is watching and taking photographs that, in short order, may become “Exhibit A” in the U.S. Attorney’s Office criminal complaint against you for securities fraud. Seriously, it is […]
Will Compliance Officers’ New Favorite Tool Be … Google Glass?
Over at the American Banker’s BankThink blog, Richard Magrann-Wells thinks he may have the perfect solution to the problem of rogue traders and other ne’er-do-well employees: Google Glass. For those of you who are unfamiliar, Google Glass is a wearable computer being developed by Google. It is mounted with a “head-mounted display” that the user wears like space […]
‘Sympathetic’ Second Circuit Rules Against Madoff Victims in Suit vs. SEC
Call me a pessimist but I’m starting to think the Madoff victims’ effort to hold the SEC accountable for their losses is not going to work out. I’ve been skeptically following the series of cases brought against the SEC under this theory since 2009. As I noted in June 2012, at least four federal district judges have […]


