Month: February 2026
Updated SEC Enforcement Manual Emphasizes Engagement and Transparency
On February 24, 2026, the US Securities and Exchange Commission (SEC) announced major updates to its Enforcement Manual (Manual), a guidance document the SEC staff uses when conducting investigations of potential securities law violations. This is the first time the SEC has updated the Manual since 2017, but the announcement […]
Major Shift in SDNY’s Voluntary Self-Disclosure Program
On February 24, 2026, the US Attorney’s Office for the Southern District of New York (SDNY) announced its revised Voluntary Self-Disclosure and Cooperation Program for Financial Crimes. The updated program focuses on increasing predictability and transparency around the self-disclosure process by offering self-reporting companies a clear path to conditional and […]
Protecting Grand Jury Materials From FOIA: Lessons From the Ninth Circuit’s Kalbers Decision
The US Court of Appeals for the Ninth Circuit’s recent decision in Kalbers v. DOJ confirms that documents produced solely in response to a grand jury subpoena are protected from disclosure under the Freedom of Information Act (FOIA). The ruling underscores how companies and counsel can preserve the confidentiality of documents by […]