In light of the DOJ’s most recent guidance on the use of personal devices and third-party messaging applications by corporate personnel, this White Paper addresses issues and challenges that companies are facing in this area...more
10/18/2023
/ CFTC ,
Compliance ,
Cybersecurity ,
Data Collection ,
Data Privacy ,
Data Protection ,
Department of Justice (DOJ) ,
Electronic Communications ,
Financial Industry Regulatory Authority (FINRA) ,
Guidance Update ,
Instant Messaging Apps ,
Mobile Devices ,
Policies and Procedures ,
Securities and Exchange Commission (SEC) ,
White Collar Crimes ,
Workplace Communication
In Short -
The Situation: On September 15, 2022, Deputy Attorney General Lisa Monaco announced significant changes and updates to the Department of Justice's corporate criminal enforcement policies. ...more
The Biden administration took office in January 2021, announcing aggressive and sweeping anticorruption initiatives to tackle corruption around the world, labeling corruption a national security priority, and signaling a...more
1/28/2022
/ Anti-Corruption ,
Biden Administration ,
Compliance ,
Corruption ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Foreign Corrupt Practices Act (FCPA) ,
National Security ,
Securities and Exchange Commission (SEC) ,
Whistleblowers ,
White Collar Crimes
In 2020, the biggest Foreign Corrupt Practices Act (“FCPA”) headline was the record-shattering global anticorruption enforcement fines and penalties collected by foreign regulators in actions involving a coordinated FCPA...more
1/13/2021
/ Anti-Corruption ,
Biden Administration ,
Bribery ,
Compliance ,
Corporate Counsel ,
Corruption ,
Criminal Investigations ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Foreign Corrupt Practices Act (FCPA) ,
Regulatory Agenda ,
Securities and Exchange Commission (SEC) ,
White Collar Crimes
We are pleased to present our annual mid-year update on financial reporting and issuer disclosure enforcement activity for 2020. This White Paper focuses on the U.S. Securities and Exchange Commission's ("SEC") enforcement...more
8/18/2020
/ Compliance ,
Coronavirus/COVID-19 ,
Corporate Governance ,
Disclosure Requirements ,
Disgorgement ,
FCPA Resource Guide ,
Financial Reporting ,
Financial Statements ,
Foreign Corrupt Practices Act (FCPA) ,
Liu v Securities and Exchange Commission ,
MD&A Statements ,
New Guidance ,
Publicly-Traded Companies ,
Regulation S-K ,
Regulation S-X ,
Rule 10b-5 ,
Rulemaking Process ,
Securities and Exchange Commission (SEC)
In the third year of the Trump Administration, the biggest Foreign Corrupt Practices Act ("FCPA") headlines were record corporate fines and penalties, and a banner year of individual FCPA enforcement highlighted by three DOJ...more
2/5/2020
/ Bribery ,
Compliance ,
Corporate Counsel ,
Corruption ,
Criminal Investigations ,
Criminal Prosecution ,
Deferred Prosecution Agreements ,
Department of Justice (DOJ) ,
Disgorgement ,
Enforcement Actions ,
Foreign Corrupt Practices Act (FCPA) ,
Government Officials ,
Securities and Exchange Commission (SEC) ,
White Collar Crimes
We are pleased to present our annual mid-year update on financial reporting and issuer disclosure enforcement activity for 2019. This White Paper primarily focuses on the U.S. Securities and Exchange Commission's enforcement...more
8/6/2019
/ Audits ,
Compliance ,
Corporate Officers ,
Department of Justice (DOJ) ,
Disclosure Requirements ,
EDGAR ,
Enforcement Actions ,
Environmental Social & Governance (ESG) ,
False Statements ,
Intent to Defraud ,
Internal Controls ,
Investment Banks ,
Lorenzo v SEC ,
Material Dissemination ,
Misleading Statements ,
Publicly-Traded Companies ,
Rule 10b-5 ,
SCOTUS ,
Securities and Exchange Commission (SEC) ,
Securities Exchange Act ,
Securities Violations
The Situation: In recent years, broker-dealers have been seeking further transparency from the Financial Industry Regulatory Authority ("FINRA") on what constitutes "extraordinary" cooperation with its investigations and when...more
On February 8, 2017, the United States Department of Justice ("DOJ") Fraud Section published a blueprint for assessing corporate compliance efforts, titled "Evaluation of Corporate Compliance Programs" ("Guidance"). It...more
3/2/2017
/ Anti-Corruption ,
Board of Directors ,
Compliance ,
Confidential Communications ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Federal Sentencing Guidelines ,
Foreign Corrupt Practices Act (FCPA) ,
Fraud ,
Internal Investigations ,
New Guidance ,
OECD ,
Policies and Procedures ,
Popular ,
Publicly-Traded Companies ,
Risk Assessment ,
Securities and Exchange Commission (SEC) ,
Senior Managers ,
Third-Party Relationships ,
Training