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Beyond Fraud: How the SEC’s Activision Case Portends Expansion of the Agency’s ESG Reach

March 28, 2023 David Peavler & Evan Singer

The Securities and Exchange Commission doesn’t regulate everything a public company does.

Or does it?

SEC practitioners are grappling with that question in the wake of the agency’s recent $35 million settlement with video game developer Activision Blizzard, where the SEC leveraged an inconspicuous internal controls rule to sanction alleged corporate conduct that had no evident impact on the company’s public reporting.

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