SEC Spotlight: Off-Channel Communications and Recordkeeping

March 9, 2023

On March 9th, Seward & Kissel partners from the Firm’s Government Enforcement and Internal Investigations Group discussed the SEC’s recent enforcement actions regarding recordkeeping failures related to employee use of personal devices. Panelists discuss how these enforcement actions have set the stage for future regulatory expectations, how they translate to potential SEC scrutiny, and what clients should consider doing in order to mitigate any issues.