This site has long followed the criminal prosecution of four former Commonwealth Edison (“ComEd”) executives and associates based on allegations of attempting to influence and rewarding the former Speaker of the Illinois House of Representatives in order to assist with the passage of legislation favorable to the electric utility company.
Bribery of a state politician is
Securities
A Collection Of Peirce’s Greatest Hits
By Mike Koehler
This site has been a big fan of SEC Commissioner Hester Peirce.
Peirce is soon to leave her position and this prior post titled “Peirce Out” highlighted a speech by the same name she delivered in which criticized various aspects of SEC enforcement – including as to the Foreign Corrupt Practices Act.
This post collects Peirce’s…
Supreme Court Allows SEC to Obtain Disgorgement Without Showing Investors Suffered a Financial Loss
By David Breyer
On June 4, 2026, the Supreme Court held in a unanimous decision that the Securities and Exchange Commission is not required to show that investors suffered pecuniary loss in order to obtain a disgorgement award in a civil enforcement action.
For a detailed summary of the ruling, see our Client Alert linked here.
Delaware Supreme Court Affirms Limits on Hypothetical Bylaw Challenges
On April 29, 2026, the Delaware Supreme Court affirmed the Court of Chancery’s dismissal of consolidated challenges to advance notice bylaws adopted in 2023 by each of The AES Corporation and Owens Corning (In re The AES Corporation and Owens Corning; one of the underlying decisions was discussed in a prior post, available…
“Peirce Out”
By Mike Koehler
This site has been a big fan of SEC Commissioner Hester Peirce.
She is soon to leave her position and a future post will highlight some of her “greatest hits” as an SEC Commissioner including her frequent criticisms of various aspects of FCPA enforcement.
Recently, Peirce delivered this speech titled “Peirce Out” in which she…
Sports, Speculation, and the Public Interest: CFTC Proposes Rules Specifying When Event Contracts Are Contrary to the Public Interest
On June 10, 2026, the Commodity Futures Trading Commission (“CFTC” or the “Commission”) published a notice of proposed rulemaking (the “NPRM”) proposing amendments to CFTC Regulation 40.11 and the addition of Appendix F to Part 40, concerning event contracts. The CFTC is proposing to specify the types of event contracts that may be deemed contrary…
SEC Proposes Major Reforms to Registered Offerings: What Public Companies Need to Know
On May 19, the Securities and Exchange Commission (SEC) proposed a sweeping set of reforms designed to modernize and simplify the framework governing registered securities offerings by public companies. The proposal, if adopted, would represent one of the most significant overhauls of the capital formation process in decades, touching on shelf registration, eligibility requirements and…
Simplifying the Public Company Framework: Understanding the SEC’s Filer Status Reform Proposal
The SEC’s proposal would consolidate the existing filer status categories by eliminating the accelerated filer and SRC designations and creating a streamlined framework consisting of large accelerated filers, non-accelerated filers, a sub-category of small non-accelerated filers and EGCs. Under the proposal, the disclosure scaling and accommodations currently available only to SRCs and EGCs would be…
Guilty Plea
By Mike Koehler
This recent post checked in on the Foreign Corrupt Practices Act enforcement action against Abraham Cigarroa Cervantes (pictured – a Mexican citizen described as a former finance director of the Latin America division of Stericycle).
In terms of background, in mid-2022, Stericycle (an Illinois based medical waste disposal company) resolved a net $59 million parallel DOJ…
A New Day, A New Plan: SEC Publishes Draft Strategic Plan for FY2026-FY2030
On June 2, 2026, the U.S. Securities and Exchange Commission (the “SEC”) published its Draft Strategic Plan for fiscal years 2026-2030, formally incorporating Chair Paul Atkins’ deregulatory and innovation-focused vision into the agency’s governing framework. The plan is organized around three strategic goals: (1) renewing regulatory policy, (2) reforming enforcement and stakeholder engagement, and (3)…