Former SEC Enforcement Director Steve Cutler once told a meeting of the DC Bar Association that "no matter how bad the underlying conduct, you can always make things worse." At the time Mr. Cutler was talking about failing to produce documents... Read More

Despite massive publicity and numerous cases by enforcement authorities, investment fund fraud actions continue to be a staple of the SEC, CFTC and the DOJ. In case after case investors are convinced to part with their hard earned cash, trusting those... Read More

The Galleon insider trading trial continues this week in New York. In another New York court room the Commission struggled to have a partial settlement approved by the court. While the agency secured the necessary approval it was not without a cost... Read More

Plan Now or Pay Later . Compliance failures are expensive. Failures result in big fines, expensive investigative costs and expensive legal fees. Plus you end up diverting valuable management resources from managing the business to managing the... Read More