Cooperation Initiative

News & Analysis as of

The Value Of Cooperation In an SEC Action

The SEC, the DOJ and other regulators frequently encourage self-reporting and cooperation with law enforcement. Taking those steps will result in “cooperation” credit that will be reflected in the charging process or when...more

International Coordination and Cooperation in Corruption Cases

Global anti-corruption enforcement is fast becoming a complicated affair. No longer can companies just focus on the FCPA, with momentary blips of concern for the UK Bribery Act....more

Capital Thinking: Education

Regulatory Activity - Online Skills Academy - Last week, the Department of Education announced its collaboration with the Department of Labor to develop a $25 million grant competition for an Online Skills...more

SEC Cooperation Agreements: With the Right Approach, Potentially a Valuable Tool for Those Facing Sanctions

Brownstein Hyatt Farber Schreck attorneys recently worked with staff in the Denver Regional Office of the U.S. Securities and Exchange Commission (“SEC”) to negotiate both a proffer agreement and a cooperation agreement on...more

SEC Enters Into First NPA With An Individual

In 2010, the SEC implemented a Cooperation Initiative designed to encourage individuals and companies to cooperate with SEC investigations. See SEC Announces Initiative to Encourage Individuals and Companies to Cooperate and...more

CFPB Offers Potential Benefits If You Turn Yourself In, But Make Sure You Understand Your Options

Brownstein Hyatt Farber Schreck’s past Client Alerts have warned that the Consumer Financial Protection Bureau’s reach touches virtually every company that has any interaction with consumers. A recent Bulletin issued by the...more

SEC Whistleblower Program: What Employers Need to Know [Video]

Attorneys Matt Allen and Todd Holleman give insights to the SEC Whistleblower Act and what employers need to know. ...more

ESMA Approves Co-Operation Agreements With 34 non-EEA Jurisdictions

The European Securities and Markets Authority (ESMA) has approved co-operation arrangements that can now be entered into between European Economic Area (EEA) financial services regulators and 34 non-EEA jurisdictions where...more

AIFMD Co-operation Arrangements Are Agreed with 34 Regulators

In an important further step towards the implementation of the Alternative Investment Fund Managers Directive (AIFMD) in the European Economic Area (EEA) on July 22, 2013, the European Securities and Markets Authority (ESMA)...more

PCAOB Issues Its First Cooperation Policy Statement

On April 24, 2013, the Public Company Accounting Oversight Board issued its inaugural “Policy Statement Regarding Credit for Extraordinary Cooperation in Connection with Board Investigations.” The Policy Statement reiterates...more

What Does Cooperation Buy You?

Cooperation. The word is filled with meaning for enforcement professionals. The U.S. Securities and Exchange Commission and the U.S. Department of Justice profess to weigh it heavily when making charging and sanctioning...more

"SEC Enforcement in the Second Term of the Obama Administration"

As the second term of the Obama administration begins, the SEC is experiencing a profound leadership transition, with the departures of agency Chair Mary Schapiro; Director of Enforcement Robert Khuzami; its general counsel;...more

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