Tag Archives: Samuel Levander

Accelerated Pace and Increased Regulatory Expectations in Enforcement and Compliance Investigations

by Joon H. Kim, Lisa Vicens, Matthew C. Solomon, Samuel Levander, and Andres Felipe Saenz

Photos of the authors

From left to right: Joon H. Kim, Lisa Vicens, Matthew C. Solomon, Samuel Levander, and Andres Felipe Saenz

The Securities and Exchange Commission (SEC) and Department of Justice (DOJ) ramped up their enforcement efforts in 2022, often in highly coordinated actions, including with other regulatory agencies such as the Commodity Futures Trading Commission (CFTC), Department of the Treasury’s Office of Foreign Assets Control (OFAC) and Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN). The DOJ also announced major policy changes regarding corporate criminal enforcement and took steps to convey its seriousness in pursuing actions against individual wrongdoers, recidivists and companies that fail to maintain effective compliance programs. The SEC was particularly active, setting its record for civil penalties and continuing its enforcement focus on insider trading, digital assets and Environment, Social and Governance (ESG) disclosures.

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Priorities, Trends and Developments in Enforcement and Compliance

by Joon H. Kim, Matthew C. Solomon, Victor L. Hou, Lisa Vicens, and Samuel Levander

2021 was a year of transition for white-collar criminal and regulatory enforcement. As courthouses reopened and trials resumed, newly-installed heads of law enforcement authorities looked to reset priorities and ramp up enforcement in the first year of the Biden administration. Policy priorities shifted toward enforcement against sophisticated financial institutions, corporates and their executives, in contrast to the previous administration’s focus on retail investors and schemes with identifiable victims. While the shift at the SEC was more immediately visible with major new enforcement priorities, investigations and resolutions, the DOJ adopted policies and announced new initiatives that will likely only find expression in 2022.

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