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SEC Warns Against Insider Trading Risks from Pandemic Fallout

Client Alert | 1 min read | 03.25.20

On March 23, 2020, the co-directors of the SEC’s Division of Enforcement, Stephanie Avakian and Steve Peikin, issued an unambiguous warning against insider trading and other illegal practices stemming from the COVID-19 fallout.  In their joint statement, the co-directors explained that “[i]n these dynamic circumstances, corporate insiders are regularly learning new material nonpublic information that may hold an even greater value than under normal circumstances.” Those with such access “should be mindful of their obligations to . . . comply with the prohibitions on illegal securities trading.”

The SEC’s co-directors emphasized that the Enforcement Division is committing “substantial resources” to combat fraud and illegal practices in these unprecedented times. Their warning comes amid extreme market volatility resulting from the pandemic, and similar statements from the DOJ about ramping up COVID-19 related enforcement efforts.

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Client Alert | 7 min read | 12.17.25

CARB Proposes Regulations Implementing California GHG Emissions and Climate-Related Financial Risk Reporting Laws

After hosting a series of workshops and issuing multiple rounds of materials, including enforcement notices, checklists, templates, and other guidance, the California Air Resources Board (CARB) has proposed regulations to implement the Climate Corporate Data Accountability Act (SB 253) and the Climate-Related Financial Risk Act (SB 261) (both as amended by SB 219), which require large U.S.-based businesses operating in California to disclose greenhouse gas (GHG) emissions and climate-related risks. CARB also published a Notice of Public Hearing and an Initial Statement of Reasons along with the proposed regulations. While CARB’s final rules were statutorily required to be promulgated by July 1, 2025, these are still just proposals. CARB’s proposed rules largely track earlier guidance regarding how CARB intends to define compliance obligations, exemptions, and key deadlines, and establish fee programs to fund regulatory operations....