News & Analysis as of

Transparency Self-Reporting

Skadden, Arps, Slate, Meagher & Flom LLP

The US Government Is Using AI To Detect Potential Wrongdoing, and Companies Should Too

The use of data analytics to identify potential violations of law has become increasingly sophisticated. Agencies like the Securities and Exchange Commission (SEC) have led the charge, employing risk-based data tools to...more

Vinson & Elkins LLP

DOJ Chooses Sticks Over Carrots: Three Reasons Why Changes to DOJ’s Corporate Enforcement Policy May Chill Cooperation by...

Vinson & Elkins LLP on

In announcing recent changes to its corporate criminal enforcement policies, the Department of Justice (“DOJ” or the “Department”) continued its forceful “tough on crime” initiatives to deter wrongdoing....more

Orrick, Herrington & Sutcliffe LLP

Recent CFTC Guidance: Cooperation, Self-Reporting, and Remediation in Enforcement Matters

On October 29, 2020, the CFTC’s Division of Enforcement (DOE) issued guidance to the enforcement staff in considering whether to recommend that a respondent receive recognition for cooperation, self-reporting, and remediation...more

Skadden, Arps, Slate, Meagher & Flom LLP

CFTC Issues New Enforcement Guidance on Cooperation Recognition in Its Orders

On October 29, 2020, the Commodity Futures Trading Commission (CFTC) Division of Enforcement (Division) issued a memorandum (Guidance) providing guidance for Division staff to follow when recommending the recognition of an...more

Skadden, Arps, Slate, Meagher & Flom LLP

DOJ Emphasizes Transparency and Encourages Cooperation

In 2019, the Criminal Division of the U.S. Department of Justice (DOJ) continued its efforts, begun a few years prior, to enhance transparency with respect to the DOJ's prosecutorial decision-making. In public statements, DOJ...more

Dechert LLP

No Reward for Good Behaviour: The Central Bank’s approach to enforcement

Dechert LLP on

On 14 November 2019, the Central Bank of Ireland (the “Central Bank”) launched its Administrative Sanctions Guidance (the “Guidance”), accompanied by a key-note speech by Derville Rowland, the Director General of Financial...more

Faegre Drinker Biddle & Reath LLP

The SEC’s SCSD Initiative Second Wave and the Applicability of the President’s Recent Executive Order

On September 30, 2019, the SEC ordered an additional 16 self-reporting investment advisory firms to pay nearly $10 million in disgorgement. Some have referred to this as the “second wave” of the SEC Division of Enforcement’s...more

UB Greensfelder LLP

“The Opinions Offered Today Are Mine Alone And Do Not Represent The Commission” — A Summary Of Recent Remarks From SEC And CFTC...

UB Greensfelder LLP on

Anyone who has sat through a talk by financial regulators is undoubtedly familiar with the refrain from the individuals that they do not speak for the Commission and that the opinions offered are their own. Even with that...more

Katten Muchin Rosenman LLP

FINRA Releases New Guidance on Credit for Extraordinary Cooperation

On July 11, FINRA released Regulatory Notice 19-23 (the Notice),1 which provides welcome details on the ways that firms and individuals can receive credit for extraordinary cooperation in connection with an investigation in...more

Morgan Lewis

FINRA Issues Additional Extraordinary Cooperation Guidance

Morgan Lewis on

Prompted by potential uncertainty regarding the interplay between FINRA Rule 4530(b) (requiring member firms to self-report certain conduct) and FINRA Rule 8210 (obligating those firms to comply with requests for information...more

WilmerHale

FINRA Issues New Guidance on Cooperation

WilmerHale on

On July 11, 2019, the Financial Industry Regulatory Authority (“FINRA”) restated and supplemented prior guidance regarding the circumstances under which FINRA will award credit for “extraordinary cooperation” in...more

King & Spalding

Above and Beyond: FINRA Clarifies Its Approach to Assessing Extraordinary Cooperation

King & Spalding on

FINRA yesterday issued long-anticipated guidance concerning credit for extraordinary cooperation in the context of enforcement investigations. Like its government counterparts, FINRA hopes to incentivize member firms that go...more

Akin Gump Strauss Hauer & Feld LLP

FERC Enforcement Releases 2017 Annual Report

• On November 16, 2017, the Federal Energy Regulatory Commission released its 11th annual Report on Enforcement, detailing the agency’s Enforcement activities in 2017. • Key highlights are that Enforcement priorities were...more

Katten Muchin Rosenman LLP

Recent FCA Commentary on Internal Investigations by Firms

On November 6, the UK Financial Conduct Authority (FCA) published a speech by Jamie Symington, director in enforcement (wholesale, unauthorized business and intelligence), on FCA-regulated firms’ internal investigations of...more

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