Foley Governance and Regulatory Alert: Determining Existence of Material Non-Public Information

On October 15, 2020, the Securities and Exchange Commission (“Commission” or “SEC”) announced settled charges against Andeavor LLC for internal accounting controls violations relating to a stock buyback plan it implemented while it was in discussions to be acquired by Marathon Petroleum Corp. in 2018. Andeavor consented to entry of the settled order finding violations of the internal controls provisions of Section 13(b)(2)(B) of the Securities Exchange Act of 1934, agreeing to pay a $20 million...
By: Foley & Lardner LLP

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