SEC enforcement Archives - Corruption, Crime & Compliance

17 Jun, 2021

First American Financial Corporation Settles SEC Case for $487,616 for Cybersecurity Data Breach and Disclosure Failures

The Securities and Exchange Commission is gaining traction in the enforcement of cybersecurity and disclosure requirements. The SEC has a lot on its plate these days – ESG, cybersecurity, and the traditional mix of enforcement cases. While the new Chairman has been chomping at the bit, he stumbled out of the gate in his selection of a new enforcement director, Alex Oh, who eventually resigned...

General

15 Dec, 2020

The Danger of Internal Controls Enforcement: The Andeavor SEC Settlement

The internal controls provision in the FCPA statute has broad application to a variety of situations beyond foreign bribery. The Securities and Exchange Commission knows full well the power of the internal controls provision and has readily applied it in a variety of circumstances. One recent example is the SEC’s settlement with Andeavor LLC for failure to publicly disclose the status of its negotiations to...