Understanding the Latest DOJ Changes to Corporate Prosecutions
The Justice Insiders Podcast: Self-Disclosure, Cooperation, and the Hazards of Knowing Too Little
The Justice Insiders Podcast - AI-Washing: Everything Old Is New Again
Understanding the Whistleblower Pilot Program in the Southern District of New York
The Presumption of Innocence Podcast: Episode 30 - Why They Do It: Inside the Mind of a White Collar Criminal – A Discussion With Author Eugene Soltes
The Justice Insiders Podcast: Using External Resources for Internal Investigations
Encouraging and Managing Employee Self-Reporting
Keeping Up With the Bureau Episode 1: Overview of CFPB and State AG Initiatives/Expansion - The Consumer Finance Podcast
The Justice Insiders Podcast: The DOJ Wants You! - Part II: Voluntary Disclosures
The Justice Insiders: The DOJ Wants You!
JONES DAY TALKS®: CFTC and DOJ Target Derivatives Trading Across Industries
Compliance Perspectives: The Antitrust Division’s Office of Decree Enforcement
Do I Need a Lawyer? Federal Employees Under Investigation [More with McGlinchey Ep. 1]
Podcast: International Risks Facing Latin America Companies
Podcast - Risk Management: Revised FCPA Corporate Enforcement Policy
FCPA Compliance and Ethics Report-Episode 165-BHP FCPA Enforcement and Lessons Learned for the Compliance Practitioner
BakerHostetler Attorneys James Mastracchio and Jay Nanavati Discuss Global Tax Enforcement
Episode 155-Mara Senn on FCPA Investigations and the Decision to Self-Disclose
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
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
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
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
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
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
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
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
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
As we enter the final quarter of 2023, the US Securities and Exchange Commission (SEC) continues to maintain an aggressive enforcement agenda. Looking ahead to 2024, companies should expect more of the same. In this webinar,...more
We return once more to the issue of public company executive perquisites or "perks" – a topic we anticipated last year would "be a hot-button enforcement issue for the foreseeable future." We were not wrong. In light of the...more
Is Your Compliance Program Designed for the Current Enforcement Landscape? Data protection, anti-corruption, antitrust, supply chains, economic sanctions and even the software employees use to communicate are all subjects...more
A non-US-based investment and brokerage firm agreed to settle spoofing allegations by the Commodity Futures Trading Commission by payment of a US $700,000 fine. In accepting this settlement, the CFTC emphasized the...more
On July 11, FINRA released Regulatory Notice 19-23 (the Notice),1 which provides welcome details on the ways that firms and individuals can receive credit for extraordinary cooperation in connection with an investigation in...more
On July 11, 2019, the Financial Industry Regulatory Authority (“FINRA”) restated and supplemented prior guidance regarding the circumstances under which FINRA will award credit for “extraordinary cooperation” in...more
In October 2005, we wrote an article titled “Cooperation, Only More So: What It Takes to Receive Credit for Cooperating with NASD.” The title came from a line in the movie Casablanca. In it, Rick (Humphrey Bogart) is asked...more
FINRA yesterday issued long-anticipated guidance concerning credit for extraordinary cooperation in the context of enforcement investigations. Like its government counterparts, FINRA hopes to incentivize member firms that go...more
Companies facing liability under the False Claims Act (FCA) often desire early resolution with the Department of Justice (DOJ) through settlement. Hand in hand with the decision to settle comes the decision of whether or not...more
For the Commodity Futures Trading Commission (CFTC or Commission), 2018 was characterized by (1) an active enforcement program emphasizing cooperation and self-reporting, (2) increasing cross-border tension over supervision...more
Introduction - The Commodity Futures Trading Commission (CFTC or Commission) recently took several steps to further encourage cooperation with and self-reporting to the Commission’s Division of Enforcement (Division). In...more
An anonymous compliance hotline within your investment adviser suddenly receives complaints about a market-beating portfolio manager. Your in-house compliance and legal team investigate and learn this portfolio manager may...more
In a time of shifting opinions on the benefits of globalization, China’s “One Belt, One Road” initiative (OBOR) offers an unexpected bright spot for multinational companies able and willing to participate in this...more
Broker-dealers with historical or ongoing instances of non-compliance with the SEC’s Customer Protection Rule are encouraged to self-report by November 1, 2016. On June 23, 2016, the Securities and Exchange...more
For years, FCPA observers have predicted that the Department of Justice (“DOJ”) will increase its prosecutions of corporate officers and employees for FCPA violations. These predictions have so far proven disputable, as the...more
Welcome to Dorsey & Whitney’s monthly Anti-Corruption Digest. In this digest, we draw together news of enforcement activity throughout the world and aim to reduce your information overload. Our London, Minneapolis, New York...more