by Anat Carmy-Wiechman and Giovanni Patti
Left to right: Anat Carmy-Wiechman and Giovanni Patti (Photos courtesy of authors)
In a new report, the NYU Pollack Center for Law & Business, in collaboration with Cornerstone Research, analyzes recent SEC enforcement trends using data from the Securities Enforcement Empirical Database (SEED). The key findings are summarized below.
by Bryce L. Friedman, Nicholas S. Goldin, Zachary Hafer, and Jeffrey Knox
From left to right: Bryce L. Friedman, Nicholas S. Goldin, Zachary Hafer, and Jeffrey Knox (photos courtesy of Simpson Thacher & Bartlett LLP)
The United States recovers in excess of $2 billion annually through False Claims Act enforcement. The Act is among the United States’ most powerful anti-fraud tools. Litigation against companies and investors under the Act is growing, in part, because the qui tam provisions of the Act allow private individuals to file litigation in the name of the United States and to obtain a percentage of any recovery. After a series of decisions from the lower federal courts, it is becoming increasingly likely that the Supreme Court will review the constitutionality of the qui tam provisions of the Act.
Photo courtesy of the author
Under the Bank Secrecy Act and regulations thereunder, financial institutions have long been required to file Suspicious Activity Reports (SARs) on a wide range of possible criminal activities with federal financial institution regulators. Over the past two decades, criminal and civil enforcement authorities have imposed BSA-related financial penalties in numerous cases for failure to file or untimely filing SARs.[1] At the same time, many in the financial sector have complained about the burdensomeness and questioned the value of SAR preparation.[2]
On October 9, the five federal financial institutions regulators (i.e., the Financial Crimes Enforcement Network, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the National Credit Union Administration, and the Office of the Comptroller of the Currency) jointly issued a document titled “Frequently Asked Questions Regarding Suspicious Activity Reporting Requirements” (SAR FAQs).[3] The SAR FAQs stated that “[t]he answers to these FAQs clarify regulatory requirements related to SARs to assist financial institutions with their compliance obligations while enabling institutions to focus resources on activities that produce the greatest value to law enforcement agencies and other authorized government users of Bank Secrecy Act (BSA) reporting.”[4]
by David Katz, Elina Tetelbaum, and Loren Braswell
From left to right: David Katz, Elina Tetelbaum, and Loren Braswell (photos courtesy of Wachtell, Lipton, Rosen & Katz)
Shareholder activism is at record levels and is no longer limited to the “proxy season.” Dozens of U.S. activist situations are underway for 2026 annual meetings, well before the windows for nominations open at most targeted companies. Activists are preparing for the fall conference circuit at which they will debut many of their 2026 campaigns, already working behind the scenes at companies by contacting their management, directors, investors, employees, sell-side analysts, and other key constituencies. Here are ten trends to expect for the year ahead.
by Avi Gesser, Diane Bernabei, and William J. Sadd
From left to right: Avi Gesser, Diane Bernabei, and William J. Sadd (photos courtesy of Debevoise & Plimpton LLP)
We recently provided a quick guide on the comparative capabilities of the various models currently available through GPT Enterprise based on our experience as lawyers using these models and OpenAI’s own recommendations. Below is an update to that guide based on our use of the new GPT-5 models since they became available to us on August 7, 2025. Again, this blog post is not a review or endorsement of any particular GenAI model.
by Avi Gesser and Michael Pizzi
From left to right: Avi Gesser and Michael Pizzi (photos courtesy of Debevoise & Plimpton LLP)
In Part 1 of this series, we “vibe coded” a game designed to help train lawyers and professional staff on the firm’s new AI policy using Generative AI. In Part 2, we demonstrate how lawyers can use AI tools to rapidly transcribe and summarize audio recordings from congressional hearings, oral arguments, or depositions, and transform them into a variety of easy-to-digest formats. Specifically, we used NotebookLM and Gamma to transcribe a recent 30-minute Second Circuit oral argument and then create a two-page written summary, a “podcast”-style audio summary, and a PowerPoint presentation—all in under nine minutes.
by Jina L. Choi, Gabriela Li, David Woodcock, and Emily Rumble
From left to right: Jina L. Choi, Gabriela Li, David Woodcock, and Emily Rumble (photos courtesy of Gibson, Dunn & Crutcher LLP)
In line with the Trump Administration’s America First Investment Policy and perhaps in response to entreaties from Congress and state regulators to protect the U.S. capital markets from unscrupulous foreign actors, the SEC announced the formation of a Cross-Border Task Force within its Division of Enforcement on September 5, 2025.[1] The task force will focus on investigating foreign-based issuers for potential market manipulation, such as pump-and-dump and ramp-and-dump schemes, and will increase scrutiny of gatekeepers, particularly auditors and underwriters, who help foreign issuers access the U.S. capital markets. The statement notably singles out China as a jurisdiction where governmental control and other factors pose unique investor risks.