‘Enforcement 40’ for 2020
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By Securities Docket on May 12, 2022, 10:54 pm
None of this is new. About a decade ago, one of my predecessors—Rob Khuzami—gave a speech about questionable behavior by defense counsel in SEC investigations. From slow-rolling document productions as I just described—to representing multiple witnesses with adverse interests in the same matter—to kicking witnesses during testimony to get them to answer questions a certain […]
By Securities Docket on May 12, 2022, 10:50 pm
The last individual FCPA enforcement action by the SEC occurred on October 14, 2020 (more than 1.5 years ago) – see here. This one year gap is the most significant gap in individual FCPA enforcement by the SEC in nearly a decade. Since late October, 2020 there have been six corporate SEC FCPA enforcement actions and […]