Offering frauds are among the most common types of enforcement actions brought by the U.S. Securities and Exchange Commission (SEC). Most of these follow a familiar path: someone raises money from investors, promising profits, only for the SEC to later allege the offering involved misstatements—or worse, outright fraud. But before the SEC can even allege fraud, it must first establish

Imagine this: You’re a mid-level executive at a healthcare company. One morning, there’s a knock at your door. It’s the FBI. You’re informed that you’re the target of a federal investigation into alleged white collar health care fraud—perhaps related to billing practices, kickbacks, or regulatory missteps. The allegations stem from a government probe—one your employer quietly self-reported after conducting an

On March 21, 2025, the SEC held its first-ever crypto roundtable, signaling a shift in its approach to digital asset regulation. The event, titled “How We Got Here and How We Get Out – Defining Security Status,” brought together a wide range of voices to examine how crypto assets should be regulated under federal securities laws. For the uninitiated, an

For clients under SEC investigation, receiving a Wells Notice can feel like the beginning of the end. And while it signals that the SEC Staff intends to recommend an enforcement action to the Commission, it also presents an opportunity — often the first and only opportunity — to present arguments directly to the Commission before charges are filed. In this

A recent decision in SEC v. Ahmed offers a stark reminder of how far the SEC will go to grab assets—even those arguably beyond what the law permits. While the Ahmed ruling itself may be defensible under the facts, it highlights a trend that practitioners and those under SEC investigation need to watch closely: the SEC is pushing the boundaries