Securities Litigation

SEC Enforcement in Financial Reporting and Disclosure—2018 Year-End Update

In 2018, the SEC continued to pursue many of the same initiatives and objectives it articulated in 2017, including emphasizing retail investor protections and keeping pace with technological change. While stand-alone enforcement actions increased in 2018, the number of financial reporting or disclosure cases continued to decline. Consistent with its public statements and despite its resource constraints in 2018, the SEC seems to be prioritizing financial reporting, internal controls, and disclosure cases impacting "Main Street" investors, particularly those involving other programmatic priorities such as crypto technologies and cybersecurity. Regardless, public companies should remain vigilant regarding potential risks, and continue to implement and maintain strong, robust controls.

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