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1st Circuit Endorses Extraterritorial Reach of the Federal Securities Laws

May 10, 2021, in SEC v. Morrone, a panel of the U.S. Court of Appeals for the First Circuit held that the federal securities laws apply to securities transactions as long as irrevocable liability occurs in the United States.

Securities Litigation Update: First Circuit Endorses Broad View of Extraterritorial Reach of the Federal Securities Laws, Cementing Split with the Second Circuit on the Meaning of a Domestic Transaction | Cadwalader, Wickersham & Taft LLP

Second Circuit Requires Detailed Facts to Satisfy Morrison s Domestic Transactions Test | Jones Day

To embed, copy and paste the code into your website or blog: The Second Circuit reemphasized that conclusory allegations that a transaction took place in the United States will not pass muster under Morrison. On March 4, 2021, the Second Circuit issued a Summary Order affirming the dismissal of securities fraud claims in Banco Safra, S.A. Cayman Islands Branch v. Samarco Mineração S.A., No. 19-3976. The court concluded that the plaintiff failed to adequately plead that its purchases of debt securities issued by a Brazilian mining company constituted domestic transactions under the U.S. Supreme Court s decision in Morrison v. National Australia Bank Ltd., 561 U.S. 247 (2010), and the Second Circuit s prior decision in

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