The proposed Department of Government Efficiency (“DOGE”) in incoming President Donald J. Trump’s administration promises an ambitious agenda of “regulatory rescission, administrative reductions and cost savings” with the goal of “mass head-count reductions across the federal bureaucracy” by July 4, 2026.[1] Many questions remain about the logistical and legal paths to accomplish these objectives.
SEC Announces Enforcement Results for Fiscal Year 2024
The Securities and Exchange Commission announced on November 22 that it filed 583 total enforcement actions in fiscal year 2024 while obtaining orders for $8.2 billion in financial remedies, the highest amount in SEC history.
The 583 enforcement actions represent a 26 percent decline in total enforcement actions compared to fiscal year 2023. Of those
Debevoise & Plimpton Discusses Key Considerations for the 2024 Annual Reporting Season
As November comes to an end, the busy annual reporting and proxy season begins for many public companies. In this Client Update, we highlight key considerations for public companies when preparing their annual reports on Form 10-K or Form 20-F, including a new exhibit filing requirement for insider trading policies. For a checklist covering these
Utah Sandbox Inspires Similar Regulatory Initiatives in Canada and other States
The regulatory sandbox modelA regulatory sandbox is a policy tool through which organizations can offer and test new models or services to assess marketability and impact, and to inform future policymaking while maintaining consumer protection. Regulatory sandboxes involve risk-based regulation and include one or more regulatory models. The regulatory sandbox model was first developed in
White & Case Discusses SEC 2025 Priorities: AI, Cybersecurity, and Crypto
On October 21, 2024, the US Securities and Exchange Commission (“SEC”) Division of Examinations (“Examination Division”) announced its 2025 Examination Priorities (“Report”). Investment advisers and broker-dealers should ensure that policies, procedures and surveillance efforts related to these priorities address concerns outlined in the Report.
The Examination Division conducts inspections of entities registered with the SEC,
Gibson Dunn Discusses New U.S. Outbound Investment Regulations
On October 28, 2024, the U.S. Department of the Treasury issued final regulations implementing an outbound investment control regime targeting AI, semiconductors, and quantum computing investments involving China that raise national security concerns. The regulations’ prohibitions and reporting requirements go into effect on January 2, 2025.
Outbound investment regulations have arrived, and with them the
Canadian Government to Ban TikTok (the Company not the App)
The Canadian government has just announced the conclusion of its national security review of TikTok and arrived at a curious conclusion: it plans to ban the company from operating in Canada but the app will remain available here. I wrote earlier this year about the need for better laws to counter the risks associated with
Debevoise & Plimpton Reviews 2024 Proxy Season
The 2024 proxy season was characterized by a high volume of shareholder proposals submitted to companies, including proposals relating to topical issues such as artificial intelligence (“AI”) and political lobbying and spending. In addition, the number of no-action requests submitted to the Securities and Exchange Commission (the “SEC”) increased compared to 2023. Based on our
Lawyers Weekly – Can GenAI outperform Australian law students?
LW write An NSW-based law lecturer recently undertook an experiment, pitting his criminal law cohort against 10 separate AI-generated responses for an end-of-semester exam. The results might surprise you. In the wake of its still-recent explosion into mainstream consciousness, much has been made of the capacity for generative AI (GenAI) to perform the duties of
Gibson Dunn Offers Securities Litigation 2024 Mid-Year Update
This update provides an overview of the major developments in federal and state securities litigation since our Securities Litigation 2023 Year-End Update. A recent NERA Economic Consulting (NERA) study provides an overview of recent developments in filings. This section highlights several notable trends.
Filing Trends
Figure 1 below reflects the federal filing rates from