Entries by Ian McGinley

SEC Rescinds Its Gag Rule Policy

The SEC yesterday rescinded its so-called gag rule policy prohibiting parties from denying the allegations in no admit/no deny settlements. The SEC also announced it would not enforce gag rule […]

New U.S. SEC Enforcement Director David Woodcock Signals Continued “Back to Basics” Approach

New SEC Enforcement Director David Woodcock used his first public remarks to signal continuity with Chairman Paul Atkins’s “back to basics” agenda, emphasizing “quality over quantity” and a focus on cases involving real investor harm rather than technical violations. Woodcock identified key enforcement priorities and announced reinstitution of the Retail Fraud Working Group to focus specifically on protecting retail investors.

The First Prediction Market Insider Trading Case: SDNY and CFTC Test the Limits of Fraud and Commodities Law

On April 23, 2026, the U.S. Attorney’s Office for the Southern District of New York (“SDNY”) and the Commodity Futures Trading Commission (“CFTC”) announced parallel criminal and civil actions against a U.S. Army service member accused of using classified military information about a planned operation to capture Venezuelan President Nicolás Maduro to place profitable trades on Polymarket, a prediction market platform. The case, the first to apply traditional insider trading and fraud theories to prediction markets, signals a shift in how the government will regulate this emerging market.  In response to this news, companies should consider reviewing company policies on insider trading and compliance to address prediction markets and the use of confidential information in connection with event-based trading.