News & Analysis as of

Self-Reporting Civil Monetary Penalty

Sheppard Mullin Richter & Hampton LLP

Federal Reserve and NYDFS Penalize Large Global Bank for BSA/AML and Other Compliance Failures

On January 19, the Federal Reserve Board (FRB) and New York Department of Financial Services (NYDFS) each issued orders settling an action against a large global bank for alleged BSA/AML violations and other compliance...more

Seward & Kissel LLP

SEC Announces Robust Fiscal Year 2023 Enforcement Results

Seward & Kissel LLP on

Who may be interested: Registered Investment Companies; Directors of Registered Investment Companies; and Investment Advisers - Quick Take: The SEC’s Division of Enforcement (Enforcement) released a report summarizing its...more

Venable LLP

New Carrot, New Stick: Commerce Encourages Voluntary Self-Disclosures and Disclosures on Others for Potential Export Control...

Venable LLP on

On April 18, 2023, the U.S. Department of Commerce, Bureau of Industry and Security (BIS) issued a policy memorandum clarifying the Office of Export Enforcement’s (OEE) policies encouraging both Voluntary Self-Disclosures...more

Vinson & Elkins LLP

FinCEN Releases New Guidelines, Highlighting The Factors To Be Considered When Bringing Enforcement Actions

Vinson & Elkins LLP on

In a significant move toward more transparency, the Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) released new guidance (the “Guidance”) on August 18, 2020, setting forth its enforcement approach and...more

Oberheiden P.C.

A CEO's Guide to FCPA Compliance

Oberheiden P.C. on

- A tone-at-the-top business culture with CEO leadership is a critical component of effective anti-corruption and anti-bribery policy implementation. - CEO leadership helps set an example for lower management and company...more

Polsinelli

Blockchain Litigation Year In Review (Part 2): Lessons From 2019 And What’s Ahead For 2020

Polsinelli on

It began as an obscure experiment in unregulated virtual currency. Initially undistinguished from Bitcoin, blockchain evolved to become one of the pillars of web 3.0, enabling new means of trust, transparency, security and...more

Troutman Pepper

Investment Management Roundtable Discussion – Regulatory and Enforcement Update

Troutman Pepper on

Gregory J. Nowak, a partner and practice leader for hedge funds in Pepper Hamilton’s Private Fund Services Practice Group, hosts a series of candid, interactive webinar discussions for West LegalEdcenter on what is going on...more

Dechert LLP

CFTC’s Enforcement Division Releases 2019 Annual Report

Dechert LLP on

The CFTC’s Division of Enforcement (Division) released its Annual Report on November 25, 2019, summarizing the Division’s activities over the past year.1 In FY 2019, the CFTC filed 69 enforcement actions, down from 83 in FY...more

Dechert LLP

SEC’s Enforcement Division Releases 2019 Annual Report: Asset Management Industry Enforcement Leads to Record Numbers

Dechert LLP on

The Enforcement Division (Division) of the Securities and Exchange Commission released its Annual Report on November 6, 2019, summarizing the year’s enforcement activity. It was a record-setting year for the Division due to...more

Dechert LLP

SEC Announces Results of Share Class Selection Disclosure Initiative

Dechert LLP on

The Securities and Exchange Commission announced on March 11, 2019 that it had settled charges against 79 investment advisers in connection with its Share Class Selection Disclosure Initiative (SCSD Initiative). This...more

Proskauer - Blockchain and the Law

Gladius Escapes Fines for Unregistered ICO after Self-Reporting to the SEC

On February 20, 2019, the SEC announced that it settled charges against Gladius Network LLC (“Gladius”) for failing to register non-exempt offers and sales of securities in violation of Sections 5(a) and 5(c) of the...more

Dechert LLP

SEC Enforcement Division Releases 2018 Annual Report

Dechert LLP on

On November 2, 2018, the SEC Enforcement Division (“Division”) released its Annual Report summarizing the past year’s enforcement activity. In the 2018 fiscal year, the first full fiscal year that Stephanie Avakian and Steven...more

Latham & Watkins LLP

New DOJ Policy Will Curb “Piling On” Multiple Penalties for Same Corporate Misconduct

Latham & Watkins LLP on

Corporate resolution policy will provide greater clarity and predictability for companies that self-report and cooperate with DOJ. Key Points: ..The new policy requires DOJ civil and criminal prosecutors to coordinate...more

Skadden, Arps, Slate, Meagher & Flom LLP

Agencies Indicate Efficient, Targeted Enforcement Priorities That Rely on Self-Disclosure

One year into the Trump administration, it remains difficult to forecast what lies ahead with respect to regulatory and white collar enforcement activity. Perhaps most instructive are recent public statements of officials at...more

Goodwin

Financial Services Weekly News - August 2016 #2

Goodwin on

Editor's Note - OATS Reporting Violations and FINRA Enforcement. FINRA’s Order Audit Trail System (OATS), is an integrated audit trail of order, quote and trade information for all NMS stocks and OTC equity securities,...more

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