On March 23, 2020, the Securities and Exchange Commission issued a stern warning against trading on nonpublic information related to the COVID-19 pandemic. In a joint statement from the SEC’s co-directors of enforcement, the SEC emphasized that “a greater number of people may have access to material nonpublic information than in less challenging times.” The message makes clear that corporate controls and procedures remain paramount in these challenging times. But, with this announcement, the SEC is also putting the investing public on notice that it recognizes “these dynamic circumstances” present a greater risk of violating the federal securities laws.
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