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Cooperation Securities and Exchange Commission (SEC)

Holland & Knight LLP

Fashion Retailer Failed to "Express" $1M in Perks But Skirts Civil Penalties

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Like a fashion trend that never fails to come back in style (we look fabulous in baggy jeans, btw), we're revisiting SEC enforcement actions involving public company executive perquisites – or "perks" – a topic we have...more

Holland & Knight LLP

Do You Hear What I Hear? DOJ, SEC Continue Promoting Merits of Self-Reporting in 2024

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2024 saw no change in the government's campaign to encourage self-reporting and cooperation. In the second installment of Season's Readings, we take a quick look at how the SEC treats self-reporting and how that differs...more

Latham & Watkins LLP

SEC Brings Charges for Failure to File Forms 13F (Investment Manager Share Positions) and 13H (Large Trader Registration)

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The SEC’s September 17, 2024, actions signal its commitment to penalize non-compliance, while encouraging market participants to self-report violations. On September 17, 2024, the US Securities and Exchange Commission...more

BCLP

SEC Penalizes Company for "Unsupported Hype"

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The SEC announced settled charges against Zymergen Inc. in connection with its IPO based on misleading statements about its market potential, revenue prospects and customer pipeline. After raising $530 million in the 2021...more

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

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

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

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

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

Nutter McClennen & Fish LLP

Nutter Securities Enforcement Update: April 18, 2024

The Nutter Securities Enforcement Update is a periodic update of noteworthy recent securities enforcement activity, settlements, decisions, and charges. We provide brief summaries that highlight recent enforcement action...more

Goodwin

SEC Speaks Conference 2024

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The SEC (U.S. Securities and Exchange Commission) recently hosted the 2024 SEC Speaks conference in Washington, DC. During the event, SEC leaders, including the Chair, commissioners, and senior staffers, shared their views...more

BakerHostetler

DOJ to Corporations - “Knock on Our Door Before We Knock on Yours”

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At last week’s ABA National White Collar Crime Institute, the leadership of the Department of Justice (the DOJ or the Department), including Attorney General Merrick Garland and Deputy Attorney General Lisa Monaco, made clear...more

WilmerHale

Global Anti-Bribery Year-in-Review: 2023 Developments and Predictions for 2024

WilmerHale on

Publicly announced Foreign Corrupt Practices Act (FCPA) enforcement activity in 2023 did not return to the levels seen a few years ago, as indicated by both the total number of cases against corporate and individual...more

Cornerstone Research

SEC Cryptocurrency Enforcement Report Summary

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Cryptocurrency enforcement continues to be a high priority for the U.S. Securities and Exchange Commission (SEC). In 2023, the SEC administration under Chair Gary Gensler brought a total of 46 cryptocurrency-related...more

American Conference Institute (ACI)

[Event] Mexico Summit on Anti-Corruption & Compliance Program - March 13th - 14th, Mexico City, Mexico

ACI’s Mexico Summit on Anti-Corruption & Compliance Programs returns on March 13-14, 2024 in Mexico City! Given the uncertainty with the looming Presidential election, as well as increased U.S. enforcement focus on Mexico...more

Thomas Fox - Compliance Evangelist

The SAP FCPA Enforcement Action-Part 4: The Fines: Self-Disclose, Self-Disclose, Self-Disclose

We continue our exploration of the SAP Foreign Corrupt Practices Act (FCPA) enforcement action. Today we go full geek in a look at the fine and penalty and most importantly what the fine and penalty communicate about what the...more

Barnea Jaffa Lande & Co.

Document Subpoena from US Authorities: Critical Steps

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Receiving a document subpoena from the DOJ, the SEC, or any other US regulatory authority is a stressful and unpleasant situation.   Things may seem even more stressful and complicated if you are a foreign national or company...more

Cornerstone Research

SEC Enforcement Activity: Public Companies and Subsidiaries—FY 2023 Executive Summary

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SEC enforcement actions against public companies and subsidiaries rose again in FY 2023, with 91 new actions filed, the third highest of any fiscal year in SEED. Although filings increased, total monetary settlements fell to...more

Holland & Knight LLP

SEC Announces Record-Setting Enforcement Results for Fiscal Year 2023

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The SEC's Division of Enforcement recently announced its Fiscal Year (FY) 2023 results, touting a record-setting year. Rather than repeat Enforcement's detailed report available here, we boil the data down to give our readers...more

Holland & Knight LLP

Cooperation with SEC: Yielding More Benefits, but Lack of Predictability Remains

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Although the SEC has long adhered to its Seaboard Report of Investigation to outline the analytical framework for the agency's cooperation program for companies, the exact benefits of self-policing, self-reporting,...more

Cornerstone Research

SEC Enforcement Actions Against Public Companies and Subsidiaries Jump in FY 2023

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Total monetary value of settlements fell to lowest level in last eight fiscal years. The U.S. Securities and Exchange Commission (SEC) filed 91 enforcement actions against public companies and subsidiaries in fiscal year...more

BakerHostetler

Culture, Cooperation and CCO Liability: SEC Enforcement Director Gurbir Grewal Gives Keynote Address at New York City Bar...

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On October 24, SEC Enforcement Director Gurbir Grewal addressed compliance professionals at the New York City Bar Association’s 2nd Annual Compliance Institute. His remarks focused on three topics: creating “a culture of...more

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