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Supreme Court Limits SEC Civil-Action Disgorgement; Raises More Questions

The Supreme Court allowed the SEC to seek “disgorgement” as a form of “equitable relief” in civil-actions, but limited the remedy to net profits for benefit of harmed investors.  Answering part of a question reserved in...more

Walmart FCPA Settlement Shines Light On Corporate Compliance Programs

June 20, 2019 – Walmart (NYSE: WMT) and its subsidiary, WMT Brasilia, agreed to a combined criminal penalty and disgorgement of $282M, together with WMT’s criminal guilty plea and undertakings in an NPA, to reach a global...more

DOJ Unveils “Yates Memo” Revisions to US Attorneys’ Manual

Speaking to a November 16 Money Laundering conference jointly sponsored by the American Banking and Bar Associations, Deputy AG Sally Yates unveiled revisions to the Department of Justice’s U.S. Attorneys’ Manual (“USAM”)....more

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