The Department of Justice’s (“DOJ”) policy regarding corporate enforcement of the Foreign Corrupt Practices Act (“FCPA”) has evolved in meaningful ways since 2016. While the policy developments themselves have been frequently...more
Junaid A. Zubairi, Chair of Vedder Price’s Government Enforcement and Special Investigations group, served as co-chair of the 2019 ALI-CLE Accountants’ Liability program on October 17 and 18, 2019 in Washington, DC. The...more
11/7/2019
/ Audits ,
Chief Compliance Officers ,
Enforcement Actions ,
Enforcement Statistics ,
FASB ,
Financial Statements ,
GAAP ,
GAAS ,
Internal Controls ,
Lucia v SEC ,
Non-GAAP Financial Measures ,
PCAOB ,
Rule 10b-5 ,
Securities and Exchange Commission (SEC)
The U.S. Securities and Exchange Commission (the “SEC” or the “Commission”) held its annual SEC Speaks conference in Washington, DC on April 8 and 9, 2019. The conference featured remarks from the Chairman and commissioners,...more
4/12/2019
/ Administrative Law Judge (ALJ) ,
Enforcement Actions ,
Foreign Corrupt Practices Act (FCPA) ,
Investigations ,
Investment Banks ,
Investors ,
Kokesh v SEC ,
Lorenzo v SEC ,
SCOTUS ,
Securities and Exchange Commission (SEC) ,
Securities Exchange Act ,
Securities Violations
On June 21, 2018, the United States Supreme Court resolved a circuit split on the question of whether administrative law judges (“ALJs”) of the Securities and Exchange Commission (the “SEC” or the “Commission”) qualify as...more
7/3/2018
/ Administrative Agencies ,
Administrative Law Judge (ALJ) ,
Administrative Proceedings ,
Appeals ,
Appointments Clause ,
Constitutional Challenges ,
Enforcement Actions ,
Final Written Decisions ,
Lucia v SEC ,
Officers of the United States ,
Remand ,
Reversal ,
SCOTUS ,
Securities and Exchange Commission (SEC) ,
Securities Violations ,
Special Trial Judges (STJs)
On March 1, 2018, the Criminal Division of the U.S. Department of Justice (“DOJ”) announced that it has expanded the scope of cases in which it will consider issuing a formal declination of criminal charges for a company that...more
3/13/2018
/ Cooperation ,
Criminal Convictions ,
Criminal Penalties ,
Declination ,
Deferred Prosecution Agreements ,
Department of Justice (DOJ) ,
Enforcement Actions ,
FCPA Corporate Enforcement Policy (CEP) ,
FCPA Guidance ,
Foreign Corrupt Practices Act (FCPA) ,
Incentives ,
Internal Investigations ,
Remediation ,
Self-Reporting
On February 21, 2018, the United States Supreme Court (the “Supreme Court”) resolved a circuit split on the question of whether the whistleblower anti-retaliation provision in Section 922 of the Dodd-Frank Wall Street Reform...more
3/6/2018
/ Anti-Retaliation Provisions ,
Digital Realty Trust Inc v Somers ,
Dodd-Frank ,
Internal Reporting ,
Reporting Requirements ,
Retaliation ,
Sarbanes-Oxley ,
SCOTUS ,
Securities and Exchange Commission (SEC) ,
Securities Violations ,
Whistleblower Protection Policies ,
Whistleblowers
The U.S. Securities and Exchange Commission (“SEC” or the “Commission”) held its annual SEC Speaks conference in Washington, DC on February 23 and 24, 2018 and provided remarks from the Chairman and commissioners, discussions...more
3/1/2018
/ Absolute Immunity ,
Administrative Law Judge (ALJ) ,
Asset Management ,
Asset Recovery ,
Broker-Dealer ,
Complex Financial Products ,
Cybersecurity ,
Enforcement Actions ,
Insider Trading ,
Investment Adviser ,
Market Abuse ,
OCIE ,
Policies and Procedures ,
Retail Investors ,
Securities and Exchange Commission (SEC) ,
Whistleblower Protection Policies