1. Home
  2. Practices
  3. Whistleblower Representation
  4. Recent Government Enforcement
  5. SEC Enforcement Actions
Have a Claim?

Click here for a confidential contact or call:

1-347-417-2192 
								
			


								
						
			


								
			

	
Whistleblower Quiz

	
Would you blow the whistle?

 Take our Quiz


									
	
						

		

			
			

				

					
SEC Enforcement Actions

					
The  Securities and Exchange Commission (SEC) is the United States agency with primary responsibility for enforcing federal securities laws. Whistleblowers with knowledge of violations of the federal securities laws can submit a claim to the SEC under the SEC Whistleblower Reward Program, and may be eligible to receive  monetary rewards and protection against retaliation by employers.


Below are summaries of recent SEC settlements or successful prosecutions. If you believe you have information about fraud which could give  rise to an SEC enforcement action and claim under the SEC Whistleblower Reward Program, please contact us to speak with one of our experienced whistleblower attorneys.

				

			

			
						
					
			

	
		
		

			

				
				
February 9, 2024

				 Five broker-dealers, seven dually registered broker-dealers and investment advisers, and four affiliated investment advisors have been ordered to pay more than $81 million in total for longstanding, widespread violations of the recordkeeping provisions of the Investment Advisers Act of 1940.  The firms were found to have failed to maintain and preserve electronic communications since at least 2019.  The firms include Northwestern Mutual Investment Services LLC, Northwestern Mutual Investment Management Co. LLC, and Mason Street Advisors LLC, who will pay $16.6 million; Guggenheim Securities LLC and Guggenheim Partners Investment Management LLC, who will pay $15 million; Oppenheimer & Co. LLC, who will pay $12 million; Cambridge Investment Research Inc. and Cambridge Investment Research Advisors Inc., who will pay $10 million; Key Investment Services LLC and KeyBanc Capital Markets Inc., who will pay $10 million; Lincoln Financial Advisors Corp. and Lincoln Financial Securities Corp., who will pay $8.5 million; U.S. Bancorp Investments Inc., who will pay $8 million; and The Huntington Investment Company, Huntington Securities Inc., and Capstone Capital Markets LLC, who will pay $1.25 million.  SEC				 					 

						
Tagged in:
													  Financial Institution Fraud, 
												
						

					
	
							
	
		
		
	


 			




	
		
		

			

				
				
January 16, 2024

				 J.P. Morgan Securities LLC (JPMS) has agreed to pay $18 million to settle charges of violating the whistleblower protection rule of the Securities Exchange Act of 1934.  According to the SEC, JPMS asked hundreds of clients who received credits or settlements over $1,000 to sign confidentiality agreements that allowed them to answer SEC inquiries, but not voluntarily contact the SEC.  SEC				 					 

						
Tagged in:
													  Whistleblower Protection Laws, 
												
						

					
	
							
	
		
		
	


 			




	
		
		

			

				
				
January 10, 2024

				 German software company SAP SE (SAP) has agreed to pay over $220 million and enter into a three-year deferred prosecution agreement with the DOJ to resolve allegations of violating the Foreign Corrupt Practices Act (FCPA) by paying bribes to government officials in Azerbaijan, Ghana, Indonesia, Kenya, Malawi, South Africa, and Tanzania from at least 2014 to 2022.  The company allegedly paid third parties to pay the bribes, then recorded the bribes as legitimate business expenses in its books and records.  To resolve parallel investigations with other authorities, SAP has agreed to pay almost $100 million to the SEC, which will be offset by a $59 million payment already made to the South African government.  DOJ; SEC				 					 

						
Tagged in:
													  Bribery and Bid-Rigging, 
													  FCPA, 
												
						

					
	
							
	
		
		
	


 			




	
		
		

			

				
				
December 26, 2023

				 A temporary restraining order was issued on December 21 against ArciTerra Companies LLC and its CEO Jonathan M. Larmore, along with Cole Capital Funds LLC, an entity formed by Larmore. Larmore and other charged entities misappropriated more than $35 million from private real estate funds and other investment vehicles to fund his family's lavish lifestyle. In another scheme, Larmore issued a press release from Cole Capital Funds, announcing they were buying 51% of WeWork's minority ownership shares at nine times the current trading price. Not disclosed was that Larmore had purchased more than 72,000 call options in the days prior to the press release. Larmore's intent was to earn a windfall on the options; instead, the press release was delayed so most of the call options expired before he could exercise them. SEC				 					 

						
Tagged in:
													  Financial and Investment Fraud, 
													  Market Manipulation and Trading Violations, 
													  Misrepresentations, 
													  Regulatory Violations, 
													  Securities Fraud, 
												
						

					
	
							
	
		
		
	


 			




	
		
		

			

				
				
December 22, 2023

				 Seven whistleblowers will receive over $28 million combined for providing information that significantly contributed to an SEC investigation. The group, comprised of a single claimant and two sets of joint claimants, provided significant and detailed information at crucial points in the investigation, saving the SEC staff considerable time and resources. SEC				 					 

						
Tagged in:
													  SEC Whistleblower Reward Program, 
													  Whistleblower Rewards, 
												
						

					
	
							
	
		
		
	


 			




	
		
		

			

				
				
December 22, 2023

				 Brooge Energy Limited, former CEO Nicolaas Lammert Paardenkooper, and former Chief Strategy Officer and interim CEO Lina Saheb settled SEC fraud charges for misstating Brooge's revenues from 2018 to 2021 connected to a $500 million securities sale. Brooge fabricated invoices to support the inflated revenues and provided them to auditors to hide the fraud. Brooge will pay a $5 million penalty for violating the antifraud, proxy statement, reporting, and books and records provisions of the federal securities laws. Paardenkooper and Saheb will each pay $100,000 and are subject to permanent officer and director bars. SEC				 					 

						
Tagged in:
													  Accounting Fraud, 
													  Misrepresentations, 
													  Securities Fraud, 
												
						

					
	
							
	
		
		
	


 			




	
		
		

			

				
				
December 13, 2023

				 Credit Suisse Securities (USA) LLC and two affiliates will pay more than $10 million for providing prohibited underwriting and advising services to mutual funds, in violation of an October 2022 Superior Court of New Jersey consent order. Per the order, Credit Suisse was prohibited from serving as principal underwriter or investment adviser to mutual funds and employees' securities companies; however, Credit Suisse acted in that capacity prior to receiving a time-limited exemption to such prohibitions in June 2023. SEC				 					 

						
Tagged in:
													  Financial and Investment Fraud, 
													  Financial Institution Fraud, 
													  Misrepresentations, 
												
						

					
	
							
	
		
		
	


 			




	
		
		

			

				
				
November 21, 2023

				 Rio Tinto plc, Rio Tinto Limited, and Rio Tinto's former CEO Thomas Albanese have agreed to entry of a final judgment, ordering it to pay $28 million and permanently restraining Rio Tinto from violating Sections 13(a) and 13(b)(2)(A) of the Exchange Act and Rules 12b-20 and 13a-16 thereunder. The judgment stems from the SEC's 2017 complaint which alleged that Rio Tinto's public filings contained misleading statements about the value of its Mozambican coal assets. Rio Tinto has agreed to retain an independent consultant to review its compliance with accounting standards. Albanese will pay a $50,000 civil penalty and is required to cooperate in the SEC's continuing investigation into Rio Tinto's former CFO Guy Elliott. SEC				 					 

						
Tagged in:
													  Accounting Fraud, 
													  Misrepresentations, 
													  Regulatory Violations, 
													  Securities Fraud, 
												
						

					
	
							
	
		
		
	


 			




	
		
		

			

				
				
November 2, 2023

				 Royal Bank of Canada has agreed to pay a $6 million civil penalty to the SEC to settle charges of violating the internal accounting controls and books and records provisions of the Securities Exchange Act.  Between 2008 and 2020, the firm failed to properly account for the costs of internally developed software.  Because it was unable to differentiate between capitalizable and noncapitalizable costs, the bank applied a single capitalization rate year after year without sufficient basis.  SEC				 					 

						
Tagged in:
													  Accounting Fraud, 
													  Financial Institution Fraud, 
												
						

					
	
							
	
		
		
	


 			




	
		
		

			

				
				
October 13, 2023

				 Avtar S. Dhillon, who chaired the boards of directors of four public companies, has been ordered to pay $10 million in connection with fraud schemes that defrauded investors worldwide of hundreds of millions of dollars.  Dhillon was allegedly complicit in schemes orchestrated by Frederick Sharp and seven other defendants that involved control persons of microcap companies illegally dumping their stock in U.S. markets.  SEC				 					 

						
Tagged in:
													  Financial and Investment Fraud, 
												
						

					
	
							
	
		
		
	


 			


											

						

								

									1
2
3
4
…
108
								

						

					

												
		
 
	
 

 



	


	

		

			

								
							
Learn about Whistleblower Rewards Programs
			
	
		

		
	
			

									

													False Claims Act					  							State & Local False Claims Acts					  							SEC Program					  							CFTC Program					  							IRS Program					  					

								See More			
	
		

	
		

	




	


	

		

			

				

					

						
Newsletter

						
Subscribe to receive email updates from the Constantine Cannon blogs

					
	
				
	
			
	
			
	
				
Sign up for: