News & Analysis as of

Enforcement Compliance Personal Liability

Venable LLP

Part 1: Cooperation in Government Investigations and Voluntary Self-Disclosure: What to Expect After DOJ’s Latest Guidance

Venable LLP on

​​​​​​​On September 15, Deputy Attorney General Lisa Monaco issued a department-wide memorandum containing revisions to the Justice Department’s (DOJ) corporate criminal enforcement policies (“the Memorandum”), including...more

Tucker Arensberg, P.C.

2022 Federal Compliance Enforcement Outlook

Tucker Arensberg, P.C. on

There is almost universal agreement regarding predictions for 2022 federal enforcement in the following areas: ..The use of fraudulently obtained COVID relief funds in both healthcare and in general, but specifically as...more

WilmerHale

Foreign Corrupt Practices Act Alert - Global Anti-Bribery Year-in-Review: 2019 Developments and Predictions

WilmerHale on

Enforcement activity reached new heights in 2019. The year saw the two largest corporate resolutions in the history of the FCPA, corporate penalties paid to US enforcement agencies topped last year’s record levels, and...more

Eversheds Sutherland (US) LLP

Recent guidance brings OFAC in line with domestic and global compliance trends

On May 2, 2019, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued guidance titled “A Framework for OFAC Compliance Commitments” (Guidance), providing direction regarding what OFAC considers to...more

Manatt, Phelps & Phillips, LLP

Is New York's Proposal a Harbinger of Things to Come? Certification of BSA/AML Compliance and Personal Liability for Mistaken or...

Why it matters - The New York Department of Financial Services (DFS) may have launched its strongest offensive yet against observed shortcomings in the Bank Secrecy Act and anti-money laundering (BSA/AML) compliance...more

Cooley LLP

SEC Sends A Message — To Executives And Their Companies

Cooley LLP on

In October 2013, SEC Chair Mary Jo White gave a speech at the Securities Enforcement Forum in which she declared an “enforcement mission” of the SEC to be implementation of the “broken windows” theory of crime deterrence...more

Morrison & Foerster LLP

Cooperation Pays in Insider Trading Enforcement and Sentencing

In This Issue: - Overview - Insider Trading Law - Insider Trading Penalties - Cooperating with the Government - Cooperating with the Department of Justice - Cooperating with the Securities and Exchange...more

Morrison & Foerster LLP

Financial Regulatory Enforcers Expanding Claims Against Individuals

In the wake of the financial crisis, federal and state regulators are increasingly taking action against individuals for alleged compliance lapses inside financial services companies, and recent reports indicate that...more

Thomas Fox - Compliance Evangelist

Individual FCPA Enforcement Actions In 2013

This year had the largest number of individual Foreign Corrupt Practices Act (FCPA) enforcement actions since 2010, the year of the Gun Sting case. Here are the highlights of FCPA related enforcement actions against...more

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