News & Analysis as of

Investigations Cooperation

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

Holland & Knight LLP

Beneficios colaborativos en casos de soborno transnacional en Colombia

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El Decreto 390 de 2024, expedido por el Ministerio de Comercio, Industria y Turismo de Colombia, establece el procedimiento para que la Superintendencia de Sociedades conceda beneficios por colaboración conforme a la Ley 1778...more

McDermott Will & Emery

[Webinar] 2024 Enforcement Outlook | Hot Topics and Emerging Trends in False Claims Investigations and Litigation - April 25th,...

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Join us for the next webinar in our Enforcement Outlook series, which will focus on the latest trends and hot topics surrounding the False Claims Act (FCA). Members of our White-Collar Practice Group will dive into how the...more

BCLP

Caught in the crosshairs: How the PRA’s new Early Account Scheme impacts individuals

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The Prudential Regulation Authority (“PRA”) has kicked-off 2024 by crystallising its new approach to enforcement. The key change is the introduction of the Early Account Scheme (“EAS”), which provides a mechanism for the...more

Womble Bond Dickinson

IRS Continues Aggressive Oversight and Enforcement of Employee Retention Credits

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The Employee Retention Credit (ERC) is a refundable tax credit for businesses whose employees were impacted by the COVID-19 Pandemic. The provisions are set out in § 2301 of the CARES Act and § 3111 of the Internal Revenue...more

American Conference Institute (ACI)

The Foreign Extortion Prevention Act: Much Ado About Nothing?

In December 2023, President Joe Biden signed the Foreign Extortion Prevention Act (FEPA) into law under the broader Fiscal Year 2024 National Defense Authorization Act (NDAA). While FEPA’s sponsors hailed it as “the most...more

Littler

DHS Announces Special Immigration Protection for Workers Who Help in Labor and Employment Agency Investigations

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The Department of Homeland Security (DHS) has recently announced a streamlined process for foreign workers to request deferred action. Deferred action is a type of prosecutorial discretion to defer removal action...more

Sheppard Mullin Richter & Hampton LLP

The Close-Out Debrief

Investigations are stressful for an organization’s leadership. But what is often overlooked is that they are stressful for an organization’s employees as well. The need-to-know nature of internal investigations usually...more

Kaufman & Canoles

NCAA Levies Sanctions Against Florida State University’s Football Program Over NIL-related Violations

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Last week, the NCAA announced its most significant Name, Image, and Likeness (NIL) enforcement action to date, imposing various penalties against Florida State University and an assistant football coach for impermissible...more

Society of Corporate Compliance and Ethics...

[Virtual Event] Corporate Compliance Enforcement Conference - July 25th, 9:00 am - 4:45 pm CT

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

Ankura

Key Compliance Takeaways from DOJ Memorandum

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“Further Revisions to Corporate Criminal Enforcement Policies Following Discussions with Corporate Crime Advisory Group” - Compliance programs play a critical role for healthcare organizations, ensuring both individuals...more

Troutman Pepper

Keeping Up With the Bureau Episode 1: Overview of CFPB and State AG Initiatives/Expansion - The Consumer Finance Podcast

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Please join Consumer Financial Services Partner Chris Willis and his guests and colleagues Ashley Taylor and Stefanie Jackman in the first episode of a special four-part series about recent developments with the Consumer...more

Health Care Compliance Association (HCCA)

OCR Investigator: Goal Is to Uncover ‘Root Cause,’ Remedy Harm From Violations

Report on Patient Privacy 21, no. 5 (May 2021) - Given the hundreds of thousands of HIPAA covered entities (CEs) and business associates (BAs) and the two dozen or so enforcement actions the HHS Office for Civil Rights...more

Jones Day

JONES DAY TALKS®: CFTC and DOJ Target Derivatives Trading Across Industries

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In an effort to pursue unlawful trading in the derivatives markets, the U.S. Commodity Futures Trading Commission ("CFTC") and U.S. Department of Justice ("DOJ") have in recent years engaged in unprecedented levels of...more

ArentFox Schiff

Deputy Associate Attorney General Sheds Light on DOJ’s FCA Priorities at Annual False Claims Act Conference

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“Enforcing the False Claims Act is a top priority for the Department—not just for our office,” said Deputy Associate Attorney General Stephen Cox, the Keynote Speaker for the 2020 Advanced Forum on False Claims and Qui Tam...more

Morgan Lewis

Practical Implications of UK Serious Fraud Office's Recent Guidance for International Organizations

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The UK Serious Fraud Office’s Corporate Cooperation Guidance has implications for organizations operating inside and outside the United Kingdom. International organizations should take the Guidance into account in practical...more

Vedder Price

FINRA Issues Supplemental Guidance on Giving Credit for Extraordinary Cooperation

Vedder Price on

On July 11, 2019, FINRA issued Regulatory Notice 19-23 to restate and supplement its prior guidance to member firms on the circumstances under which FINRA awards credit for providing "extraordinary cooperation" during an...more

Jones Day

FINRA Clarifies When Credit for Extraordinary Cooperation Will Be Awarded in Investigations

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The Situation: In recent years, broker-dealers have been seeking further transparency from the Financial Industry Regulatory Authority ("FINRA") on what constitutes "extraordinary" cooperation with its investigations and when...more

Katten Muchin Rosenman LLP

FINRA Releases New Guidance on Credit for Extraordinary Cooperation

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

Maynard Nexsen

Commandment #2: Don't Panic. Be Calm. And Don't Self-Medicate! - When the Feds Come Knockin'

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After 35 years of dealing with civil, regulatory, and federal criminal investigations (both as a federal prosecutor and as a civil and criminal defense attorney), I realized understanding the judicial process and mapping out...more

WilmerHale

FINRA Issues New Guidance on Cooperation

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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

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

WilmerHale

CFTC Releases Enforcement Manual in Hopes of Increasing Transparency

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Intending to bring greater transparency to the operation of its enforcement program, the Commodity Futures Trading Commission’s (CFTC or Commission) Division of Enforcement (the Division) recently, for the first time, made...more

Akin Gump Strauss Hauer & Feld LLP

Yates Memo Revisions Encourage Cooperation, but Fail Fully to Achieve a Common-Sense Approach to Civil Enforcement

• Recent Justice Manual changes roll back Yates memo requirements for corporations seeking cooperation credit in enforcement actions, including civil enforcement actions. • Corporations can now receive maximum cooperation...more

Blank Rome LLP

DOJ Revises Yates Memo and Relaxes Approach to Corporate Cooperation Credit

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The Department of Justice (“DOJ”) announced that it is stepping back from its hard-line approach to corporate cooperation credit in which a corporation was not eligible for credit unless it disclosed all relevant facts about...more

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