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Cooperation

The Volkov Law Group

SEC Outlines “Effective Cooperation” Standard

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The Securities and Exchange Commission is catching up to DOJ.  Not in enforcement but in transparency. After years of criticism, the Justice Department has set the gold standard for transparency and providing guidance on...more

Thomas Fox - Compliance Evangelist

The Boston Consulting Group Declination: A Money Shot for Clawbacks

In a recent development that has garnered significant attention in the compliance community, the U.S. Department of Justice (DOJ) declined prosecution of Boston Consulting Group, Inc. (BCG) for violations of the Foreign...more

WilmerHale

Obligations for Deployers, Providers, Importers and Distributors of High-Risk AI Systems in the European Union’s Artificial...

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In this blog post, we will focus on obligations that the European Union’s Artificial Intelligence Act (AI Act) sets for deployers, providers, importers and distributors regarding high-risk AI systems....more

Fox Rothschild LLP

IRS Reopens Employee Retention Tax Credit Voluntary Disclosure Program

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The ERC is a legitimate, refundable tax credit designed to help businesses that continued to pay employees while they were shut down because of the COVID-19 pandemic or that experienced a significant decline in gross receipts...more

WilmerHale

DOJ Rolls Out Corporate Whistleblower Pilot Program

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On August 1, 2024, the Department of Justice officially launched a three-year pilot program to reward whistleblowers who report corporate misconduct....more

Barnea Jaffa Lande & Co.

Israel’s Money Laundering and Terror Financing Prohibition Authority Updates List of At-Risk Countries of the FATF

The international Financial Action Task Force (FATF) recently issued two announcements updating the list of countries and jurisdictions at high risk of money laundering, terrorist financing, and proliferation financing, and...more

Holland & Knight LLP

Modificación del régimen sancionatorio ambiental en Colombia

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Hay siete novedades relevantes que las empresas en Colombia deben tener en cuenta con ocasión de la sanción de la Ley 2387 del 25 de julio de 2024, que modifica el régimen sancionatorio ambiental contenido en la Ley 1333 de...more

Royer Cooper Cohen Braunfeld LLC

Is Your Compliance Program Active or Passive? It Matters.

The SEC's Director of the Division of Enforcement, Gurbir S. Grewal, outlined five principles of effective cooperation with the SEC during his keynote address at the Securities Enforcement Forum West 2024 conference...more

Husch Blackwell LLP

The Justice Insiders Podcast - AI-Washing: Everything Old Is New Again

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Host Gregg N. Sofer welcomes Husch Blackwell attorney Rebecca Furdek back to the show to discuss recent government inquiries and enforcement actions concerning products and services related to artificial intelligence (AI)....more

Latham & Watkins LLP

10 Key Takeaways Developments in International Cartel Enforcement and Observations From Workshop

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Latham’s Antitrust & Competition Practice provides insight on the current state of enforcement, including more expansive views of what constitutes a cartel, enhanced detection tools, and what to expect next....more

WilmerHale

Antitrust Division’s Implementation of the Department of Justice’s Safe Harbor Declination Policy - A Policy in Search of a Fact...

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The Antitrust Division of the Department of Justice quietly made a change to its Leniency Policy and Procedures (the “Leniency Policy”) that could impact companies acquiring businesses or companies that they discover may have...more

Fox Rothschild LLP

California’s CPPA Partners with France’s CNIL to Safeguard Personal Information

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Is California going to start policing CCPA violations like the French police GDPR violations? The California Privacy Protection Agency (CPPA) and France’s Commission Nationale de l’Informatique et des Libertés (CNIL)...more

Fenwick & West LLP

Securities Law Update - June 2024

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Welcome to the latest edition of Fenwick’s Securities Law Update....more

White & Case LLP

SEC Enforcement Director Outlines His View of Effective Cooperation

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In February 2024, we published an alert discussing the significant benefits of prompt self-reporting and cooperation during a US Securities and Exchange Commission ("SEC") investigation. This past week, during his keynote...more

Holland & Knight LLP

Collaboration Station: Director Grewal Touts Benefits and Efficiency of Cooperation

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In recent remarks at the Securities Enforcement Forum West 2024, U.S. Securities and Exchange Commission (SEC) Director of the Division of Enforcement Gurbir Grewal extolled the benefits of and expounded on the elements of...more

BakerHostetler

SEC Enforcement Director Grewal Doubles Down on Encouraging Self-Reporting

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In a recent interview with Law360, Securities and Exchange Commission (SEC) Enforcement Director Gurbir Grewal reiterated the agency’s commitment to the encouragement of voluntary self-reporting, going as far as to say that...more

Skadden, Arps, Slate, Meagher & Flom LLP

Decoding AFA’s Guide: A Comparison of Sponsorship and Charitable Donations in France, the US and the UK

On March 26, 2024, the French Anti-Corruption Agency (AFA) published a guide on how to engage in corporate sponsorship and charitable donation activities while appropriately mitigating corruption risks (the Guide)...more

Snell & Wilmer

The Department of Justice Offers Individual Corporate Wrongdoers a “Get Out of Jail Free Card” in New Voluntary Self-Disclosure...

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The Department of Justice’s Criminal Division (DOJ) recently announced a Pilot Program on Voluntary Self-Disclosures for Individuals (the Individual VSD Pilot Program or Pilot Program), which allows certain individuals...more

The Volkov Law Group

DOJ Heralds New Voluntary Self-Disclosure Program for Individuals

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On April 15, 2023 Nicole Argentieri, Principal Deputy Assistant Attorney General and the Head of the U.S. Department of Justice’s (“DOJ’s”) Criminal Division, announced a new voluntary self-disclosure program for individuals...more

Robinson & Cole LLP

Department of Justice Criminal Division Announces Voluntary Self-Disclosure Pilot Program for Culpable Individuals

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Last week, the Department of Justice (DOJ) announced the Criminal Division’s Pilot Program on Voluntary Self-Disclosures for Individuals (the Program). Pursuant to the Program, “an individual who voluntarily self-discloses...more

Mintz

DOJ’s Criminal Division Announces Pilot Program on Voluntary Self-Disclosure for Individuals

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Drawing on a carrot and stick approach, Department of Justice (“DOJ” or the “Department”) guidance in 2023 focused heavily on incentivizing companies to voluntarily self-disclose their misconduct. This guidance included the...more

Society of Corporate Compliance and Ethics...

Understanding the Whistleblower Pilot Program in the Southern District of New York

In January 2024 the US Attorney’s Office for the Southern District of New York (SDNY) set a shockwave through the business world by announcing a new whistleblower pilot program. To understand what the policy says and what it...more

Latham & Watkins LLP

SFO Announces Ambitious Five-Year Plan

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The Serious Fraud Office’s strategy for 2024 to 2029 indicates aspiration to be a more effective agency and to incentivise personnel. On 18 April 2024, the UK’s Serious Fraud Office (SFO) published an ambitious, albeit...more

Venable LLP

DOJ Announces Pilot Program for Individual Voluntary Self-Disclosures

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On April 15, 2024, the Department of Justice (DOJ) criminal division announced a new pilot program designed to reward individuals with non-prosecution agreements (NPAs) who voluntarily self-disclose "actionable, original...more

Dorsey & Whitney LLP

DOJ’s Criminal Division Launches New Self-Disclosure Pilot Program for Individuals

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On April 15, 2024, the U.S. Department of Justice (DOJ)’s Criminal Division announced a new pilot program that will allow and encourage individuals involved in specific types of corporate criminal conduct to voluntarily...more

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