Self-Reporting

News & Analysis as of

Every U.S. Life Sciences Company Needs an Export Control Compliance Program (No, Really….)

Two recent settlements by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) confirm that every U.S. life sciences company engaging in exports should have an effective U.S. export control compliance...more

The Foreign Corrupt Practices Act’s One-Year “Pilot Program” Nears The Halfway Mark

The Foreign Corrupt Practices Act (“FCPA”) prohibits both United States and foreign corporations and nationals from offering or paying, or authorizing the offer or payment, of anything of value to a foreign government...more

FCPA Compliance---Recent Department of Justice Initiatives

The Department of Justice (DOJ) recently initiated a one-year pilot program to encourage companies to self-report violations of the Foreign Corrupt Practices Act (FCPA). Any company contemplating self-reporting such a...more

Agencies Provide Information on Self-Assessments for Diversity Policies and Practices

The federal banking agencies (the “Agencies”) have provided information explaining how regulated financial institutions may begin to submit self-assessments of their diversity policies and practices as of year-end 2015. The...more

MDE Self-Disclosure Can Limit, Even Eliminate Risk of Environmental Penalties

Maryland entities that voluntarily discover and disclose environmental violations can still receive penalty reductions, or even complete forgiveness, under the rarely invoked Maryland Department of the Environment (MDE)...more

Thinking Like a Prosecutor – Yates and Internal Investigations

I respect prosecutors, most of them at least. I had the fortunate opportunity to work with a number of terrific prosecutors. Most are intelligent, hard working and committed to doing the right thing. I recognize that there...more

SEC Settles With 71 Municipal Issuers

The Commission’s Municipalities Continuing Disclosure Cooperation Initiative has been a significant success. Under the Initiative the agency has filed settled enforcement actions against firm’s representing 96% of the market...more

The Spring Meeting Confronts the Yates Memo: Execs in the Front Lines of Corporate Criminal Responsibility; Presentation of the...

The Business Law Section’s Director and Officer Liability Committee conducted a program at the Section’s Spring Meeting in Montréal. The program focused on the recent Yates memorandum of the U.S. Department of Justice (DOJ),...more

Financial Services Weekly News - August 2016 #2

Editor's Note - OATS Reporting Violations and FINRA Enforcement. FINRA’s Order Audit Trail System (OATS), is an integrated audit trail of order, quote and trade information for all NMS stocks and OTC equity securities,...more

5 Keys to New AZ IC Law

We have repeatedly blogged on the Pushmi-Pullyu world of independent contractor relationships, a world in which employers can do no right. (DOL Says Employers Are Morons) Well, Arizona recently enacted a law providing at...more

Prevailing in an Era of Regulatory Enforcement – Balancing Risk and Compliance [Expect Focus – Vol. II, July 2016]

IN THE SPOTLIGHT - - SEC Sanctions Unregistered EB-5 Investments Broker SECURITIES - - FINRA to Assess Member Firms’ Culture - SEC Seeks Fund Responses to Distribution-In-Guise Guidance...more

New SFO Bribery Case: Can’t Pay? That Might Be Okay…

The UK Serious Fraud Office has entered its second deferred prosecution agreement (DPA) with a company accused of bribery. Links to the SFO press release, and the detailed preliminary and final judgments of the court are...more

The UK’s second DPA: a hopeful judgment

The approval of the Deferred Prosecution Agreement (DPA) between the Serious Fraud Office (SFO) and XYZ Limited (XYZ) by Leveson LJ on 8 July 2016 has generated much breathless commentary, not least because it is only the...more

Compliance, Cooperation Mitigates FCPA Liability with DOJ-SEC

Well designed compliance systems coupled with solid internal controls can be instrumental in preventing violations of the FCPA. Despite best of efforts, there is no doubt that even a well-constructed compliance system can be...more

DOJ’s First Corporate Enforcement Action Under Pilot Program

In April 2016, the Department of Justice (DOJ) announced its Foreign Corrupt Practices Act Enforcement Plan and Guidance, which includes a one-year pilot program to incentivize individuals and companies to voluntarily...more

SEC Announces Customer Protection Rule Initiative

Broker-dealers with historical or ongoing instances of non-compliance with the SEC’s Customer Protection Rule are encouraged to self-report by November 1, 2016. On June 23, 2016, the Securities and Exchange...more

Airline Industry Alert: FAA Does Not Recommend Routine Psychological Testing for Pilots

On June 9, 2016, the FAA announced specific actions that it will take, in conjunction with airlines and pilots' unions, concerning pilots' mental health in response to the Malaysia Flight 370 and Germanwings Flight 9525...more

UK Bribery Act – 5 lessons in 5 years: No. 4 – International Hurdles

The SFO has spread its wings. It has visibly increased its efforts to investigate companies for bribery and corruption offences and in the last year it has had success with a new weapon: the Section 7 UK Bribery Act...more

UK Bribery Act – 5 lessons in 5 years: No. 3 – Incentivising Self-Reporting

Bribery by its very nature is generally a secret matter. Self-reporting is therefore a useful tool by which the SFO can learn of, and take action against, wrongdoing. But what are the incentives for a company to self-report?...more

The UK Bribery Act: SFO Procedures and DPA Process

A couple of recent articles about the UK Serious Fraud Office (SFO) caught my attention. One was on thebriberyact.com, entitled “Opinion: DPA’s must show greater benefits. We discuss the Criteria & Process for a DPA set out...more

Mainbrace: June 2016 (No. 3)

As the July 1, 2016, effective date for the SOLAS Regulation VI/2 amendments quickly approaches, unanswered questions and difficulties complying with varied international and domestic implementations loom large. In an effort...more

This Week In Securities Litigation

The elements of an insider trading claim continued to be a key focus this week. The first circuit, following prior circuit precedent, held that a personal benefit based on a long term friendship and a steak dinner was...more

USDOJ Beefs Up FCPA Efforts

In April, the Fraud Section of the United States Department of Justice announced several measures designed to enhance its effort to discover and prosecute violations of the Foreign Corrupt Practices Act (FCPA). See, 15 U.S.C....more

SFO Spells Out What It Means By "Cooperation"

In a speech on 18 May 2016 Matthew Wagstaff, Joint Head of Bribery and Corruption at the Serious Fraud Office, spoke about what the Serious Fraud Office regards as proper cooperation. Michelle de Kluyver, Counsel at Allen &...more

Legal Landscape: SBA Expands the WOSB/EDWOSB Contract Program, Importance of the Economic Loss Rule and Self-Reporting Requirement...

Welcome to the fourth edition of Legal Landscape, a series we have developed with Onvia’s blog to provide government contractors with a quick, but thorough, summary of important legal developments and regulations in...more

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