The US Securities and Exchange Commission (SEC or Commission) had an active fourth quarter, rounding out a record-breaking calendar year that saw several significant enforcement actions and regulatory developments. The SEC Division of Enforcement's (Enforcement) vigor with respect to cryptocurrency enforcement continued in full force with high-profile enforcement actions against crypto companies and employees, while also diligently pursuing more traditional enforcement actions for insider trading and Foreign Corrupt Practices Act (FCPA) violations. On the regulatory side, the Commission proposed a number of rules and amendments aimed at, among other things, strengthening investor protection in connection with insider trading, standardizing best execution practices for broker-dealers, and promoting transparent and accessible information-sharing with investors.
This Advisory continues our series of quarterly SEC enforcement and regulatory highlights, with links to additional Arnold & Porter advisories when available. Our analysis is informed by our experience as former leaders and attorneys in the Enforcement Division at the SEC: Dan Hawke as the former Chief of the Market Abuse Unit and Director of the Philadelphia Regional Office, Jane Norberg as the former Chief of the Office of the Whistleblower and a Senior Officer in the Division of Enforcement, and Christian Schultz as former Assistant Chief Litigation Counsel.
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