Subject to Inquiry

Subject to Inquiry

THE LATEST ON GOVERNMENT INQUIRIES AND ENFORCEMENT ACTIONS

Government Investigations and White Collar Litigation Group

Noreen Kelly

Photo of Noreen Kelly Noreen serves as the chair of McGuireWoods’ Government Investigations and White Collar Litigation Department, which Law360 selected for its prestigious “Practice Group of the Year” award for its notable work in 2019, and is a member of the firm’s Diversity & Inclusion Committee. Noreen focuses her practice on regulatory enforcement matters and commercial litigation in the securities and financial services spaces.

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FINRA Enforcement Previews Initial CAT Enforcement Philosophy

By Noreen Kelly, Nellie E. Hestin and Helen J. Moore on Securities and Commodities
On May 18, 2023, during an “Ask FINRA Senior Staff” panel held as part of FINRA’s 2023 Annual Conference, Christopher Kelly, Acting Head of FINRA Enforcement, provided a first look into how FINRA Enforcement intends to address CAT reporting violations as the industry nears the three-year anniversary of the first Phase of CAT go-live and… Continue Reading

Update on FINRA’s Use of CAT Data – They Are “Just Scratching the Surface”

By Noreen Kelly, Nellie E. Hestin and Helen J. Moore on Securities and Commodities
During FINRA’s 2023 Annual Conference held on May 16-18, 2023, several panels provided insight into how FINRA is currently using CAT data for market surveillance and how FINRA plans to use the data going forward to both develop more sophisticated surveillance reviews and further promote industry-wide efficiencies. … Continue Reading

U.S. Attorneys’ Offices Adopt Policy Incentivizing Self-Disclosure of Corporate Misconduct

By Noreen Kelly, Benjamin A. O'Neil, Casey Erin Lucier, Edwin O. Childs, Amy Manning, Angelo Russo, Sarah A. Zielinski, Elissa Baur and Joshua Wade on Compliance, Enforcement and Prosecution Policy and Trends
On Feb. 22, 2023, U.S. Attorneys’ Offices throughout the country adopted a new policy that incentivizes corporate voluntary self-disclosure of misconduct.  Deputy Attorney General Lisa Monaco’s Sept. 15, 2022 memorandum (“Monaco Memo”) instructed all DOJ sections to review their policies incentivizing corporate voluntary self-disclosure or, if no formal written policy existed, to draft and publish… Continue Reading

U.S. Supreme Court Rules Time Limits Apply to SEC Disgorgement Orders

By Louis D. Greenstein, Noreen Kelly, William E. Goydan, James C. Freije, Government Investigations Group and McGuireWoods LLP on Enforcement and Prosecution Policy and Trends, Securities and Commodities
A unanimous United States Supreme Court held Monday, in Kokesh v. Securities and Exchange Commission, that the five-year statute of limitations under 28 U.S.C. § 2462 applies to disgorgement sought by the Securities and Exchange Commission. Previously, the Circuits had been split on this issue. The issue in Kokesh was straightforward. Kokesh appealed a trial… Continue Reading

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