Posted by Tami Stark, Claudette Druehl and Robert DeNault, White & Case LLP, on Tuesday, September 10, 2024
Editor's Note:
Tami Stark is a Partner, Claudette Druehl is a Counsel, and Robert DeNault is an Associate at White & Case LLP. This post is based on their White & Case memorandum.
On August 14, the U.S. Securities and Exchange Commission (“SEC”) announced yet another wave of enforcement actions related to widespread “off-channel communications,” charging an additional 26 firms with failing to maintain employee communications on personal devices which related to the firms’ business. [1] The new settlements add nearly $400 million to the billions in civil penalties that the SEC has collected from more than 50 firms over the last few years for recordkeeping failures related to off-channel communications. [2]