On February 24, 2026, the SEC Division of Enforcement (“Division”) released the first updates to its Enforcement Manual (“Manual”) since 2017. The updates—which the SEC characterized as underscoring its “ongoing commitment to fairness, transparency, and efficiency in the investigations conducted by the Division”—are an important window into the Division’s expected approach to investigations and will influence strategic decision-making by respondents and their counsel. While many early commentators have described the changes as significant, the revisions are better understood not as a sharp break from the past, but as a formalization of approaches the Division has employed in recent years with targeted enhancements layered on top.
Continue Reading SEC Enforcement Division Revises Its Playbook: What the Updated Manual Signals About Enforcement Practices and Defense Strategy

SPACs, or “blank check” Special Purpose Acquisition Companies, have surged over the past two years, raising over $75 billion (about half the total US IPO market) last year alone. Recent SEC statements add complexity to accounting and disclosure rules for SPACs and could chill the market. Even so, De-SPAC (the merger of a SPAC into a private company, taking it public) transactions will trigger more M&A and PIPE deals at least through 2022.
Continue Reading SPACs Fuel Hot M&A and IPO Markets – Will SEC Cool the Fire?

On April 15, 2021, U.S. President Joseph Biden signed an executive order (the “Executive Order”) that establishes a new authority for imposition of additional sanctions targeting the Russian Federation in response to Russia’s “continued and growing malign behavior.”
Continue Reading U.S. Announces Expanded Sanctions Targeting Russia

On February 4, 2021, the US Federal Trade Commission (“FTC”) and the US Department of Justice (“DOJ”) jointly announced that they would immediately suspend the common practice of granting “early termination” of the initial 30-day waiting period under the Hart-Scott-Rodino Act (“HSR Act”).
Continue Reading FTC & DOJ Announce Temporary Suspension of HSR Act “Early Termination” and New HSR Act Thresholds