To discuss and analyze the US Securities and Exchange Commission’s (SEC’s) FY 2017 Annual Report, which details its priorities for the coming year and evaluates enforcement actions that occurred during FY2017.
Summarizes key shifts from FY 2016, outlines the Enforcement Division’s current priorities, and, in view of its stated focus on the conduct of investment professionals and protection of retail investors, provides guidance to the investment management industry as it gears up for the coming year.
The Report provides insight into changes in the SEC’s approach to enforcement actions, including a general shift in tone suggesting a more measured approach to enforcement and remedies and a move away from a statistics-oriented approach, and a glimpse into its priorities for the coming year, including five core principles guiding the Division’s enforcement decisions.
As those in the asset management industry consider revisions to their policies and procedures for FY 2018, as well as their risk profile more generally, they should keep in mind key insights into the Commission’s enforcement strategy offered by the Report.
Practical guidance from experienced securities enforcement, litigation, compliance and anti-corruption lawyers.
Solomon, M.C., Bergen, R.M. and Collins, A. (2018), "SEC releases enforcement division FY 2017 annual report: shift in tone and likely approach", Journal of Investment Compliance, Vol. 19 No. 1, pp. 15-19. https://doi.org/10.1108/JOIC-02-2018-0015
Emerald Publishing Limited
Copyright © 2018, Cleary Gottleib Steen & Hamilton.