Self-Reporting

News & Analysis as of

Alstom Joins Santa’s Naughty List – In a Very Big Way

The North Pole for Foreign Corrupt Practices Act (FCPA) enforcement action announcements seems to have temporarily moved south for the month of December. Last week there was the final announcement of the long-standing Avon...more

Dallas Airmotive, Inc.'s FCPA Matter Offers Practical Insights and Continuing Lessons

On December 10, 2014, DOJ filed a criminal Information alleging (i) conspiracy and (ii) violation of the bribery provisions of the FCPA against Dallas Airmotive, Inc., an aircraft engine maintenance, repair and overhaul...more

2014 FERC Enforcement Report Emphasizes Internal Compliance Procedures, Self-Reporting, and Importance of Cooperation

The Federal Energy Regulatory Commission’s (FERC) Office of Enforcement (Enforcement) 2014 Report on Enforcement (Report), issued on November 20, 2014, provides an overview of and statistics regarding FERC’s enforcement...more

Prosecuting Individuals for Financial Crimes - Some Questionable Recent Ideas

The government must be very sensitive about all the criticism it has been getting, from Congress, some judges and others, for not prosecuting more individuals for financial crimes. Perhaps in response, senior government...more

DOJ and SEC Officials Focus on Enforcement, Self-Reporting and Compliance at International FCPA Conference

From November 18 to 19, 2014, the American Conference Institute held its annual U.S. Foreign Corrupt Practices Act (FCPA) conference outside of Washington, D.C. Keynote speakers including U.S. Department of Justice (DOJ)...more

Chamber of Commerce: Corporations Form the Cornerstone of FCPA Compliance

Recently one of the most unlikely sources for praise of the Foreign Corrupt Practices Act (FCPA) came out to inform us all that corporations are the cornerstone of FCPA compliance and enforcement. You may be surprised to find...more

Timeline For A Work Injury

A problem we see a lot of is when a worker gets hurt at work, tells his boss like he’s supposed to but is told to give it a day or two before he goes to the company nurse or to the doctor. Another problem we see a lot is...more

The definitive guide to Corporate Self Reporting

We have aggregated below the SFO guidance on Self Reporting (available on its website on a number of pages) and importantly recent comments from the Director about it. If you are considering Self Reporting as an option we...more

Top 4 Benefits of Self-Reporting FCPA Violations

Violations of the U.S. Foreign Corrupt Practice Act (FCPA) can lead to significant fines and serious consequences, leaving many to wonder why an organization would opt to voluntarily disclose violations. This is exactly what...more

A New Special Tax Adjustment Monitoring And Administrative Measure

Advanced Alert and Voluntary Tax Adjustment - The SAT released a short bulletin named "The Announcement on Issues Related to Special Tax Adjustment Monitoring and Administration" (SAT Bulletin [2014] No. 54 Bulletin...more

Critical SEC Deadline Fast Approaching: December 1 Deadline for Issuers and Obligated Persons to Participate in the SEC’s MCDC...

While underwriters choosing to participate in the Securities and Exchange Commission’s (“SEC”) Municipalities Continuing Disclosure Cooperation Initiative (the “MCDC Initiative”) were required to self-report violations by...more

OFCCP Issues Two New “FAQs”

The OFCCP recently added two new “FAQs” to its website to help explain contractors’ obligations under new Section 503 and VEVRAA regulations. The first addresses the information contractors must maintain related to efforts to...more

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

Deadlines Applicable to Colleges and Universities Approaching for Participation in SEC’s Continuing Disclosure Cooperation...

On March 10, 2014, the Securities and Exchange Commission (“SEC”) announced a voluntary self-reporting program for issuers and underwriters of municipal bonds for reporting of inaccurate statements made in offering documents...more

Update: SEC Extends Deadline for Issuers to Participate in SEC’s Municipalities Continuing Disclosure Cooperation (MCDC)...

The Securities and Exchange Commission (SEC) has extended the deadline for issuers and obligors to self-report potential violations of their continuing disclosure obligations from the original deadline of September 10, 2014...more

SEC Extends Municipalities Continuing Disclosure Cooperation Initiative Self-Reporting Deadline For Issuers and Obligated Persons...

The Securities and Exchange Commission released a statement on July 31, 2014, modifying certain aspects of its Municipalities Continuing Disclosure Cooperation Initiative (the “MCDC Initiative”). The MCDC Initiative provides...more

SEC Enforcement Division Modifies Municipalities Disclosure Initiative

On July 31, the SEC announced modifications to its Municipalities Continuing Disclosure Cooperation (MCDC) Initiative that will (i) allow issuers and obligors more time to complete their reporting requirements by extending...more

SEC Modifies MCDC Initiative in Response to Industry Concerns

On July 31, 2014, the Securities and Exchange Commission extended the Municipalities Continuing Disclosure Cooperative Initiative (“MCDC”) deadline to allow issuers and obligors more time to complete their reporting...more

SEC Extends the MCDC Initiative Self Reporting Deadline

The Securities and Exchange Commission (“SEC”) just announced modified provisions of the Municipal Continuing Disclosure Cooperation Initiative (“MCDC Initiative”) that extends the self-reporting period for issuers and...more

SEC Modifies MCDC Initiative

On July 31, 2014, the Securities and Exchange Commission (SEC) issued a press release regarding an extension of the deadline for its Municipalities Continuing Disclosure Cooperation initiative (MCDC). The extended deadline...more

SEC Makes Modifications to Municipalities Continuing Disclosure Cooperation (MCDC) Initiative

The Securities and Exchange Commission (SEC) recently announced modifications to its Enforcement Division’s Municipalities Continuing Disclosure Cooperation (MCDC) Initiative. First, the SEC has extended the deadline from...more

Industry Concerns Prompt SEC To Modify MCDC Initiative

In response to concerns raised by industry participants, the Securities and Exchange Commission (SEC) has made some modifications to its Municipalities Continuing Disclosure Cooperation Initiative (MCDC Initiative). The SEC...more

Federal Register Round Up – June/July 2014

DOD Proposed Rules Seeking Contractor Business System Rule Self Assessments - The Department of Defense issued a proposed rule on July 15th that would revise the DFARS Business Systems Rule by requiring contractors...more

The Clock is Ticking on the SEC’s MCDC Initiative - Limited Self Reporting Window Closes September 9, 2014

The U.S. Securities and Exchange Commission (the “SEC”) has announced its Municipalities Continuing Disclosure Cooperation Initiative (the “MCDC Initiative”) for municipal issuers, conduit borrowers, other obligated persons...more

Low-Tech Proof In a High-Tech World: Northern District of California Denies Class Certification In Hulu Data Privacy Case

On June 16, the Northern District of California denied a motion for class certification in In re Hulu Privacy Litigation, No. C 11-03764 LB, ECF No. 111. The plaintiffs in that action alleged that Hulu violated the Video...more

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