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Personal Liability Enforcement

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

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

Latham & Watkins LLP

10 Key Focus Areas for UK-Regulated Financial Services Firms in 2024

Latham & Watkins LLP on

In this publication, we explore some of the core focus areas for UK-regulated financial services firms in the year ahead. 2023 saw significant progress on the regulatory reform agenda, and many measures consulted on or...more

Goodwin

Bank Officer and Director Enforcement Exposures In the Wake of Silicon Valley Bank

Goodwin on

The recent and sudden failures of Silicon Valley Bank and Signature Bank, and the threat of other bank failures, have led to intense public focus on what caused these banks to run into trouble, who is to blame, and what...more

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

BakerHostetler

The Deeper Dive: C-Suite to Prison Pipeline

BakerHostetler on

In recent years, the U.S. Department of Justice (DOJ) has been criticized for failing to prosecute executives for fraud, particularly in the financial sector. In response, the DOJ has begun to more heavily emphasize...more

Brooks Pierce

Speech by DOJ’s Marshall Miller Could Be Harbinger of Bad Things to Come

Brooks Pierce on

So here’s a thing. Last week Marshall Miller, the No. 2 official in the Justice Department’s Criminal Division, made a speech urging corporations to focus its investigations into misconduct on individual malefactors and...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

K&L Gates LLP

Individual Liability in CFPB Enforcement Proceedings

K&L Gates LLP on

To date, the CFPB has brought 12 cases—out of more than three dozen total CFPB enforcement cases—in which it named individuals as defendants or respondents liable for violations of consumer protection statutes. Below, we...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

Dechert LLP

Financial Services Quarterly Report - Fourth Quarter 2013: Political Intelligence Firms – Insider Trading and Enforcement Shifts...

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Insider trading remains a top priority for the Securities and Exchange Commission (SEC) and Department of Justice (DoJ). In fiscal year 2012, the SEC filed 58 enforcement actions against 131 individuals and entities and the...more

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