News & Analysis as of

Self-Reporting Cooperation New Guidance

Skadden, Arps, Slate, Meagher & Flom LLP

UK Serious Fraud Office Releases New Guidance on Self-Reporting, Cooperation and Deferred Prosecution Agreements

On 24 April 2025, the Serious Fraud Office (SFO) released new guidance on corporate self-reporting, cooperation and deferred prosecution agreements (DPAs)....more

White & Case LLP

A step towards transparency or the devil is in the detail? Analysing the effectiveness of the SFO’s new Corporate Guidance

White & Case LLP on

More than a decade ago, the concept of the Deferred Prosecution Agreement (DPA) became part of UK law. Ever since, there has been considerable uncertainty as to exactly what conditions a company needs to meet in order to be...more

Morrison & Foerster LLP

UK Serious Fraud Office Issues New Guidance on Corporate Cooperation and Enforcement

On 24 April 2025, the UK’s Serious Fraud Office (SFO) published new guidance for companies on cooperation and enforcement in relation to corporate criminal offending (Guidance). The Guidance outlines the SFO’s key...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

CFTC Unveils Replacement Penalty Mitigation Policy Focused on Self-Reporting, Cooperation, and Remediation

The Commodity Futures Trading Commission (CFTC), an independent U.S. government agency that regulates the U.S. derivatives markets, including futures, options, and swaps, has announced a new policy for mitigating potential...more

Baker Botts L.L.P.

CFTC Issues Enforcement Advisory Adopting New Approach for Consideration of Self-Reporting, Cooperation, and Remediation

Baker Botts L.L.P. on

On February 25th, the Commodity Futures Trading Commission (CFTC or Commission) adopted a new approach for how the Division of Enforcement (Division) will assess self-reporting, cooperation, and remediation efforts when...more

Skadden, Arps, Slate, Meagher & Flom LLP

Decoding AFA’s Guide: A Comparison of Sponsorship and Charitable Donations in France, the US and the UK

On March 26, 2024, the French Anti-Corruption Agency (AFA) published a guide on how to engage in corporate sponsorship and charitable donation activities while appropriately mitigating corruption risks (the Guide)...more

Skadden, Arps, Slate, Meagher & Flom LLP

CFTC Issues New Enforcement Guidance on Cooperation Recognition in Its Orders

On October 29, 2020, the Commodity Futures Trading Commission (CFTC) Division of Enforcement (Division) issued a memorandum (Guidance) providing guidance for Division staff to follow when recommending the recognition of an...more

Jones Day

DOJ Policy Increases Incentives for Self-Reporting of Potentially Willful Trade Violations

Jones Day on

The Situation: The U.S. Department of Justice ("DOJ") has issued guidance revising its 2016 voluntary disclosure policy to provide companies stronger incentives to voluntarily self-report apparent potentially willful trade...more

Dechert LLP

No Reward for Good Behaviour: The Central Bank’s approach to enforcement

Dechert LLP on

On 14 November 2019, the Central Bank of Ireland (the “Central Bank”) launched its Administrative Sanctions Guidance (the “Guidance”), accompanied by a key-note speech by Derville Rowland, the Director General of Financial...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

Latham & Watkins LLP

UK SFO Releases Guidance on Corporate Cooperation Credit

Latham & Watkins LLP on

Guidance sets out the SFO’s expectations for investigations but leaves open questions, particularly for cross-border investigations. On 6 August 2019, the UK Serious Fraud Office (SFO) issued its much-anticipated Corporate...more

Jones Day

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

Jones Day on

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

WilmerHale

FINRA Issues New Guidance on Cooperation

WilmerHale on

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

A&O Shearman on

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

King & Spalding

Above and Beyond: FINRA Clarifies Its Approach to Assessing Extraordinary Cooperation

King & Spalding on

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

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