SEC Enforcement Sweeps: Implications for Agency and Industry
Author: Adam Aderton.; Melissa Taustine.
Source: Volume 56, Number 08, April 15 2023 , pp.113-117(5)
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Abstract:
The SEC is increasingly conducting sweep investigations to address market conduct. In the past 18 months, the SEC has instituted enforcement actions arising from five different enforcement sweeps involving at least 65 respondents and more than $1 billion in related penalties. These actions are typically focused on violations of strict liability or negligence-based provisions by market participants directly regulated by the SEC. The SEC’s use of enforcement sweeps presents benefits and risks for both the agency and respondents.Keywords: Recordkeeping Sweeps; Pay-to-Play; Custody Rule; Regulation S-ID; Form CRS
Affiliations:
1: Willkie Farr & Gallagher LLP; 2: Willkie Farr & Gallagher LLP.