SEC PUBLISHES ENFORCEMENT MANUAL
Overlooked in the flurry of recent events, the SEC’s Enforcement Division made public its revised Enforcement Manual, its comprehensive reference manual for Enforcement Staff. It includes guidance about prioritizing cases, inter-agency referrals and cooperation, litigation procedure, privilege, and criminal referrals. The Manual directs staff to rank investigations based on “programmatic importance” (e.g. expressed SEC priorities), magnitude of the violations, and SEC resources required to investigate possible violations.
OUR TAKE: The Enforcement Manual is the SEC’s playbook for conducting investigations. It is a must-read for those responsible for implementing and executing compliance programs.