Review of SEC 10-Ks Shows 700% Increase in AI Disclosures, "Sets Stage for Litigation"

SEC’s 700% Increase in AI Disclosures Sets Stage for Litigation

Artificial intelligence-related disclosures have expanded rapidly across industries. A review of Form 10-K filings from S&P 500 firms during fiscal years 2019–2024 shows a sharp rise in companies that referenced AI and shifts in where AI disclosures appear in annual reports.

By 2024, all industries in the S&P 500 index included AI-related disclosures. Mentions increasingly appeared in the 10-Ks’ “Risk Factors” section—signaling that companies view AI as a potential material source of risk, meaning they’re seen as a key uncertainty impacting the organization’s financial performance, operations, reputation, or interests.

As AI disclosures become more frequent, they’re more likely to be treated as significant, or “material.” Monitoring these developments over time enables attorneys and experts to identify emerging benchmarks and trends, which in turn helps determine aspects of AI reporting that are most relevant to regulatory actions and private litigation.

Polymarket, Kalshi: Betting on Jesus Can Save You From Insider Traders

On the face of it, gambling on the second coming of Jesus Christ is just funny. Would earthly dollars even matter if the Messiah did return? Still, more than $3 million was wagered between hopeful believers and doubtful skeptics on Polymarket last year; in the final three months of 2025, activity on prediction markets took off and weekly wagers topped $2 billion.

There was one big advantage to the Jesus bet, whether punters went for Yes or No: It was at least a trade where everyone could be fairly sure that no one in the market had inside information. That’s not the same for a growing number of high-profile events where winning positions have been ramped up suspiciously just before the outcome was revealed.

Ex-Jefferies Banker Pleads Not Guilty to UK Insider Dealing Charge

An ex-banker at Jefferies Financial Group Inc.’s UK arm pleaded not guilty to an insider dealing charge brought by the markets watchdog.

The Financial Conduct Authority charged Bobosher Sharipov with allegations that he leaked insider information in 2021 to a business associate while advising GCP Student Living Plc on a potential takeover bid.

The FCA has said that the associate, Bekzod Avazov, is alleged to have used this insider to information to make a profit of nearly £70,000. Avazov also entered into a not guilty plea on Wednesday at Southwark Crown Court.

Time to Move On: The SEC Was Right to Retire the Global Research Analyst Settlement

The Global Research Analyst Settlement (GRAS) was an important enforcement response to misconduct over 20 years ago by 12 firms that had published biased research to curry favor with investment banking clients during the dot-com era. In addition to fines and other sanctions, the GRAS imposed special undertakings on these firms to address conflicts of interest between their research and investment banking functions.

Recently, the SEC consented to amendments to the GRAS that terminated these undertakings in recognition of changes that have been made to the regulatory regime for equity research.

The SEC made the right decision. Like most enforcement undertakings, the GRAS restrictions were never meant to last in perpetuity. Indeed, express language in the GRAS presumed they would eventually be retired once an enhanced regulatory framework was established that would apply to all firms, not just the original 12 subject to the GRAS. And in fact, actions by Congress, the SEC and FINRA have accomplished just that: creating a robust regulatory regime to safeguard the integrity of equity research that amply justifies retiring the GRAS.