June 20, 2016
Transcript: “Yes, It’s Time to Update Your Insider Trading Policy”
We have posted the transcript of our popular webcast: “Yes, It’s Time to Update Your Insider Trading Policy.” The transcript for our Non-GAAP webcast – the one that almost broke the Internet – will be up in a few days…
DTCC Re-Proposal: Imposition of Chills & Global Locks
Hat tip to McDermott Will’s Gary Emmanuel for informing me that DTCC has re-proposed a rule change with the SEC that would establish the circumstances under which DTC would impose and/or release a ‘Deposit Chill’ or a ‘Global Lock’ on a security. It also sets forth the proposed criteria for releasing these restrictions – and the procedures that would allow an issuer to challenge the restriction.
This re-proposal was necessary after DTC withdrew its prior rule – that it submitted over two years ago – in the face of negative comments…
DOJ’s FCPA Pilot Program: First Declinations & Rare NPAs
Recently, as noted in this memo, the DOJ issued the first public declinations of a criminal enforcement action since implementing its new “Pilot Program” enforcement plan when it declined prosecution of Akamai and Nortek for FCPA violations by their respective Chinese subsidiaries.
On the same day, both companies separately entered into non-prosecution agreements (“NPAs”) with the SEC, only the second and third FCPA NPAs from the SEC…
You gotta love any SEC case that uses the phrase “Bacchanalian Adventure”…
– Broc Romanek