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Sarah Razaq Sallis

Leveraging her experience in the Financial Industry Regulatory Authority’s (FINRA’s) Department of Member Regulation and more than a decade in private practice at global firms, Sarah helps clients confidently navigate securities regulations and implement compliance strategies aligned with their business models.

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On September 30, 2026, the United States Court of Appeals for the Third Circuit revived a putative securities fraud class action against Ocugen, Inc., a small, publicly traded pharmaceutical company, holding that a stock’s rapid price recovery after a corrective disclosure cannot, on its own, prove that an earlier misstatement was immaterial. In re Ocugen, Inc. Securities Litigation, No. 25-2653 (3d Cir. Sept. 30, 2026). The decision abrogates what the court itself labeled the “Oran-Burlington rule,” a line of Third Circuit precedent stretching back nearly 30 years. For practitioners defending or bringing Section 10(b) claims in Pennsylvania, New Jersey, or Delaware federal courts, the ruling removes a familiar tool from the motion-to-dismiss toolkit and replaces it with a more fact-intensive materiality inquiry.

On September 30, 2026, the University of Missouri-Kansas City School of Law hosted the inaugural Heartland Government Enforcement & Investigations Conference. The day-long program brought together federal prosecutors, judges, state regulators, in-house counsel, and private practitioners across seven substantive sessions spanning DOJ enforcement priorities, federal sentencing and discovery practice, healthcare fraud, legal ethics and artificial intelligence, state antitrust enforcement, internal investigations, and securities and commodities regulation. Below is a summary of each session.

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On August 18, 2026, the Securities and Exchange Commission (SEC or the Commission) charged the former CEO, CFO, and Senior Director of Finance of a Texas-based auto lending company with securities fraud in connection with the collapse of the subprime auto lender. The SEC’s press release and the complaint filed the same day in the U.S. District Court for the Southern District of New York lay out what the SEC alleges was a years-long scheme to keep a failing lender’s securitization pipeline alive by using collateral that, according to the SEC, was in significant part either nonexistent or already pledged to other parties.

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On August 18, 2026, the Securities and Exchange Commission (the SEC or the Commission) proposed a new rule, titled “Regulation Crypto Assets,” that would create a tailored securities offering regime for certain investment contracts involving crypto assets (the Proposal). The Proposal is the SEC’s first attempt at formal crypto rulemaking, following the Commission’s March 2026 interpretation clarifying how the federal securities laws apply to certain crypto assets and transactions involving crypto assets.

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An AI agent scans a news alert, identifies a market opportunity, and places a trade in your brokerage account—all before you finish your morning coffee. This is not a hypothetical. It is the premise of Robinhood’s recently launched Agentic Trading platform, and it is a consequential development in AI-enabled financial services. It also arrives as the two primary federal regulators of U.S. financial markets, the Securities and Exchange Commission (SEC) and the Commodity Futures Trading Commission (CFTC), are actively building out AI governance frameworks.

gavel on a money

Earlier this month, the U.S. Supreme Court issued its 9-0 decision in Sripetch v. Securities and Exchange Commission, holding that the U.S. Securities and Exchange Commission (SEC) can retrieve ill-gotten gains from alleged securities-law violators without having to prove that victims of those violations suffered a pecuniary loss.[1] Sripetch is the most recent decision in a series of U.S. Supreme Court cases analyzing the SEC’s disgorgement powers.

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On February 24, 2026, the Securities and Exchange Commission’s Division of Enforcement announced sweeping revisions to its Enforcement Manual (the Manual). A central feature of the revisions is a redesigned Wells process, which gives investigation targets a chance to be heard before the Commission authorizes an enforcement action. Most notably, the revised manual instructs staff to provide Wells notice recipients with “salient, probative evidence” before a response is due, addressing the information imbalance that has traditionally characterized SEC investigations. Then, on May 18, 2026, the SEC announced a second major pro-defendant shift: it rescinded Rule 202.5(e)—the decades-old “no-deny” policy that had required settling defendants to agree not to publicly deny the agency’s allegations as a condition of settlement.

After years of regulatory uncertainty, the SEC and CFTC are moving toward a unified approach to digital asset oversight, launching a joint harmonization initiative to align definitions, streamline compliance, and reduce fragmentation. For crypto and financial services firms, this effort signals clearer pathways for product development and cross‑market operations—though lasting certainty will hinge on sustained…