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Compliance Department of Justice (DOJ) Cooperation Initiative

Compliance programs typically refer to formalized institutional procedures within corporations and organizations to detect, prevent and respond to indvidual and widespread instances of regulatory violations. ... more +
Compliance programs typically refer to formalized institutional procedures within corporations and organizations to detect, prevent and respond to indvidual and widespread instances of regulatory violations.  In response to many corporate scandals evidencing rampant unethical business practices, many nations, including the United States, began passing strict regulatory frameworks aimed at curbing these abuses. Notable pieces of legislation in this area include the U.S. Foreign Corrupt Practices Act (FCPA), Sarbanes-Oxley (SOX), and the U.K. Bribery Act, to name a few. The foregoing statutes and the severe penalties often associated with them form the basis of many modern institutional compliance programs. less -
A&O Shearman

FINRA Releases New Guidance On Extraordinary Cooperation Credit

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On July 11, 2019, FINRA provided additional guidance on obtaining extraordinary cooperation credit to supplement its prior enforcement guidance. FINRA Regulatory Notice 19-23, FINRA Investigations: FINRA Supplements Prior...more

Harris Beach PLLC

Column: Achieving a culture of compliance

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Simply having a compliance program is no longer enough in today’s legal and regulatory climate. In the eyes of regulators, “check the box” or “paper” compliance programs are as good as not having one at all. Organizations...more

Dorsey & Whitney LLP

DOJ, SEC Change “Cooperation Credit” Process, Add Resources to Fight Corruption

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During recent speeches Deputy Attorney General Sally Yates and SEC Enforcement Division head Andrew Ceresney announced changes to the processes the DOJ and the SEC will use to decide if a company will receive “cooperation...more

Dorsey & Whitney LLP

The Value Of Cooperation In an SEC Action

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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

Miller Canfield

SEC Whistleblower Program: What Employers Need to Know

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Attorneys Matt Allen and Todd Holleman give insights to the SEC Whistleblower Act and what employers need to know. ...more

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