Key takeaways

• In early September, the SEC announced four separate enforcement actions involving executives and other senior personnel arising out of securities law violations by four different corporations.
• The SEC’s willingness to bring civil proceedings against the individuals that allegedly caused the corporations to engage in, or were complicit in, the proscribed conduct may portend renewed determination by the SEC to hold executives and directors, as well as outside professionals, accountable for securities fraud and disclosure violations committed by corporations.
• The SEC’s actions highlight the need for directors and senior management to maintain a sharp focus on their company’s controls and disclosure practices.