Insights

Washington – January 2, 2020: Crowell & Moring elected eight lawyers to the firm’s partnership, effective January 1, 2020. The firm also promoted seven attorneys to the position of senior counsel, and 26 associates to the position of counsel. The new partners have been promoted from within the ranks of the firm’s Washington, Los Angeles, and San Francisco offices. The new partners have been promoted from across offices and practice groups, including White Collar & Regulatory Enforcement, Health Care, International Trade, Intellectual Property, Privacy & Cybersecurity, Government Contracts, Litigation, and Antitrust.

Washington – November 5, 2019: Crowell & Moring’s White Collar & Regulatory Enforcement Group has been named to the Global Investigation Review’s 2019 “GIR 100” list, which honors the world’s leading firms for corporate investigations. This marks the fifth consecutive year that the firm has been recognized for this honor.

On September 30, 2024, the SEC announced the settlement of an enforcement action against Marathon Asset Management, L.P. (Marathon) for failing to implement proper policies and procedures to prevent the misuse of material nonpublic information (MNPI).  The issue stemmed from Marathon’s participation in ad hoc creditors’ committees, where the firm inadvertently received MNPI through its consultants and advisers.  This enforcement action highlights the SEC’s intense focus on the participation by investors in ad hoc creditors’ committees and the importance of implementing robust MNPI controls when doing so.

On August 26, 2024, the U.S. Securities and Exchange Commission announced that it had settled charges with Sound Point Capital Management, LP, a New York-based registered investment adviser, for inadequate policies and procedures regarding its handling of material nonpublic information (“MNPI”) and related compliance deficiencies in its collateralized loan obligations (“CLOs”) trading activities. Sound Point agreed to pay a $1.8 million civil penalty in addition to other remedial measures. Notably, the SEC did not charge the investment adviser or its employees with violating SEC Rule 10b-5.

On October 24, 2023, Gurbir S. Grewal, Director of the U.S. Securities and Exchange Commission’s (“SEC”) Division of Enforcement, provided a preview of the agency’s enforcement outlook against Chief Compliance Officers (“CCO”) in the upcoming year.  His remarks highlight the continued importance of compliance programs (and continued focus on the part of regulators on those programs), but also make clear that SEC enforcement actions targeting behavior on the part of CCOs will continue to be rare.

The program covers the preservation of the attorney client privilege during internal investigations and will examine both the basics of privilege law and best practices for preserving it in the U.S. Attendees will find this program very beneficial for members of the compliance, internal audit, and legal functions.