David Woodcock discusses the SEC's renewed focus on financial reporting and disclosure violations. Mr. Woodcock examines how the SEC's enforcement division is bringing more cases in this area and is investigating more matters than it has in several years. He also notes that the SEC's enforcement policy is more focused on cases that involve internal control claims, as well as targeting high-level individuals that may result in criminal prosecutions. As a consequence, companies should carefully design and implement internal controls to prevent fraud and accounting errors. In addition, companies should be vigilant in encouraging whistleblowers to report internally and to avoid retaliating against them.
A partner in Jones Day's Securities Litigation & SEC Enforcement Practice, Mr. Woodcock is former Regional Director of the SEC's Fort Worth Regional Office, As Regional Director, Mr. Woodcock was responsible for all aspects of the SEC's enforcement and examination activities in Texas, Oklahoma, Arkansas, and Kansas. He also served as Chair of the cross-office/division Financial Reporting and Auditing Task Force, designed to enhance the SEC's detection and prosecution of violations involving accounting and false financial statements, and as a member of the Enforcement Advisory Committee. During his time at the SEC, Mr. Woodcock oversaw investigations involving public company disclosure and reporting; the Foreign Corrupt Practices Act (FCPA); insider trading; and investigations of major financial institutions, investment advisors, hedge funds, and broker-dealers.
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