On November 22, the Securities and Exchange Commission (SEC) announced its enforcement results for fiscal year (FY) 2024. As compared to FY 2023, the Division of Enforcement (the division) reported a 26% decline in the total volume of enforcement actions filed, accompanied by a $3.2 billion increase in the orders obtained for financial remedies. Below is a high-level summary of the division’s FY 2024 statistics and key takeaways regarding the division’s substantive focus.
Isabela Herlihy
Isabela is an associate in the firm’s White Collar + Government Investigations Practice Group. As a legal intern at the Foundation for Individual Rights in Education, Isabela researched and drafted memoranda on legal issues regarding free speech and due process in higher education and assisted the Individual Rights Defense Program team in writing and editing legal correspondence to students, professors, and campus groups whose civil liberties have been violated.
SEC v. Ripple Labs, Inc.: XRP Considered an Unregistered Security in Institutional Sales but Not in Programmatic Sales or Other Distributions
In a long-awaited decision in SEC v. Ripple Labs, Inc., U.S. District Judge Analisa Torres of the Southern District of New York held that Ripple Labs, Inc.’s (Ripple) XRP token is not, in and of itself, a security requiring registration. Although the decision is being regarded by many as a victory for both Ripple and the crypto industry, the nuances in the decision may result in an appeal from both sides.