Navigating Pay-To-Play Compliance in an Election Year and Beyond

The 2024 U.S. Presidential election is grabbing the headlines right now. However, 469 other federal elections, 13 gubernatorial elections, and countless contests at the state and local levels will be decided in November. With so many candidates and campaigns, the risk of pay-to-play and political donation rule violations, even unintentional ones, is high.

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MNPI Remains a High Risk Area for Compliance

Failing to adequately manage Material Non-Public Information (MNPI) remains a high-risk area for compliance, as evidenced by recent actions in the United States, the United Kingdom and across the globe for issues including insufficient insider trading compliance policies, market abuse and failure to effectively manage insider information.

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SEC Enforcement and Priorities Set Compliance Expectations for 2024

2023 was another active year for U.S. Securities and Exchange Commission (SEC) enforcement, encompassing a wide range of violations against individuals and firms of all sizes.  

Understanding 2023 enforcement actions along with the agency’s 2024 enforcement priorities will help firms better assess and anticipate regulatory expectations—and set the stage for better compliance. 

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SEC Priorities Focus on MNPI, Insider Trading and Crypto

Temperatures are hot across the United States right now – and so is U.S. Securities and Exchange Commission (SEC) enforcement activity. The last few weeks have seen a flurry of Insider Trading actions from the U.S. Securities and Exchange Commission and the Department of Justice against individuals ranging from a Chief Compliance Officer to a Chief of Police.

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Optimal OBA Compliance Goes Beyond Just Disclosures

It’s 4PM on a Friday. You were hoping to wrap up for the day to start your weekend, but there’s a deal to be closed. The CEO is looking for confirmation that there are no conflicts around outside business activities or any other potential conflicts of interest, and he needs that info stat.

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