Bridging the Week by Gary DeWaal: November 12 - 16 and November 19, 2018 (New Employee Orientation; Whistleblowing; ICOs and SEC Path Forward)

Published Date: November 19, 2018

The Commodity Futures Trading Commission’s Division of Enforcement issued its annual report last week; it said the purpose of its enforcement program was to engender a “true culture of compliance.” The Division suggested the measure of success for such culture would be evidenced by a company's chief executive officer threatening new employees during orientation that the company itself would advise law enforcement authorities if they ever violated the company’s internal control requirements. Not exactly the warmest and fuzziest welcome aboard message! Separately, the SEC fined two companies for engaging in initial coin offerings without registration. The SEC also obligated the companies – and they agreed – to pay back initial investors, upon request, the amount of their ICO purchases as well as to file registration statements for their digital tokens. In contemporaneously issued guidance, the SEC said these settlements offered a path forward for other companies previously involved in ICOs. As a result, the following matters are covered in this week’s edition of Bridging the Week:

Because of the United States Thanksgiving holiday, the next regularly scheduled edition of Bridging the Week will be December 3.

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Gary DeWaal

Gary DeWaal is currently Special Counsel with Katten Muchin Rosenman LLP in its New York office focusing on financial services regulatory matters. He provides advisory services and assists with investigations and litigation.

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Gary DeWaal
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