News & Analysis as of

Self-Reporting Enforcement Actions Corporate Governance

Skadden, Arps, Slate, Meagher & Flom LLP

CFTC Director of Enforcement Provides Insight on Recent Advisory

On March 27, 2025, the Futures Industry Association hosted a webinar with Brian Young, the director of the U.S. Commodity Futures Trading Commission (CFTC) Division of Enforcement. Although he noted that the opinions...more

DLA Piper

CFTC issues new enforcement advisory on self-reporting, cooperation, and remediation

DLA Piper on

The Commodity Futures Trading Commission (CFTC, or Commission) has issued an enforcement advisory detailing how its Division of Enforcement (Division) will evaluate self-reporting, cooperation, and remediation from companies...more

Morrison & Foerster LLP

New CFTC Advisory Incentivizes Self-Reporting, Cooperation, and Remediation

The Advisory sets out factors that the Enforcement Division will use to rate self-reporting and cooperation. This rating places a company or individual within a “tier” used to determine the Mitigation Credit amount available....more

Skadden, Arps, Slate, Meagher & Flom LLP

CFTC Announces New Enforcement Advisory on Self-Reporting, Cooperation and Remediation

On February 25, 2025, the Division of Enforcement of the Commodity Futures Trading Commission (CFTC or the Commission) issued an advisory to Division staff on how to evaluate self-reporting, cooperation and remediation credit...more

Vinson & Elkins LLP

New CFTC Enforcement Policy Increases Penalties to Deter Recidivists

Vinson & Elkins LLP on

The U.S. Commodity Futures Trading Commission (“CFTC” or “Commission”) — the federal agency tasked with regulating the U.S. derivatives markets, which includes futures, swaps and certain kinds of options — has recently taken...more

Skadden, Arps, Slate, Meagher & Flom LLP

2024 Insights: Enforcement and Litigation

Expert Allegations Could Become More Frequent in Securities Fraud Complaints and Possibly Erode Pleading Standards - A Ninth Circuit panel ruling that plaintiffs could use expert analysis to bolster securities fraud claims...more

Sheppard Mullin Richter & Hampton LLP

DOJ Touts Emerging Results from New Corporate Crime Self-Reporting Initiatives

The Department of Justice’s recent criminal self-reporting policy changes are beginning to show results, according to Assistant Attorney General Kenneth Polite Jr. Speaking at the New York City Bar Association’s White Collar...more

Holland & Knight LLP

Executive Perks: A Hammer Finds Its Nail in SEC Settlement with Tool Company

Holland & Knight LLP on

We return once more to the issue of public company executive perquisites or "perks" – a topic we anticipated last year would "be a hot-button enforcement issue for the foreseeable future." We were not wrong. In light of the...more

Baker Donelson

Companies Take Heed: DOJ Announces Key Updates and Corporate Compliance Guidance

Baker Donelson on

On March 3, 2023, Assistant Attorney General Kenneth Polite delivered the keynote speech at the 38th Annual National Institute on White Collar Crime of the American Bar Association (ABA) in Miami, Florida. AAG Polite's speech...more

Arnall Golden Gregory LLP

Government Investigations Team Insights - February 2023

AGG’s Government Investigations Team Insights provides periodic updates covering legal and regulatory topics. Our team, which includes former federal prosecutors, SEC enforcement attorneys, and federal agency attorneys, has...more

Skadden, Arps, Slate, Meagher & Flom LLP

DOJ Doubles Down on Efforts To Incentivize Early Self-Reporting and Cooperation

On January 17, 2023, the U.S. Department of Justice (DOJ) announced revisions to the Criminal Division’s Corporate Enforcement Policy. The revisions follow Deputy Attorney General (DAG) Lisa Monaco’s September 2022...more

Vinson & Elkins LLP

DOJ Chooses Sticks Over Carrots: Three Reasons Why Changes to DOJ’s Corporate Enforcement Policy May Chill Cooperation by...

Vinson & Elkins LLP on

In announcing recent changes to its corporate criminal enforcement policies, the Department of Justice (“DOJ” or the “Department”) continued its forceful “tough on crime” initiatives to deter wrongdoing....more

Husch Blackwell LLP

DOJ's New Policies Encourage Voluntary Self-Disclosure, Compensation Tied to Compliance

Husch Blackwell LLP on

In a speech given at NYU on September 15, 2022, Deputy Attorney General Lisa Monaco reviewed new and enhanced Department of Justice (DOJ) policies regarding criminal enforcement related to corporate entities. Assistant...more

Pietragallo Gordon Alfano Bosick & Raspanti,...

DOJ Reveals New Corporate Enforcement Strategy

Takeaway: Changes in DOJ corporate compliance programs focus on prompt reporting and self-disclosure, and individual accountability. Companies can protect their interests by creating a diligent, comprehensive risk-based...more

NAVEX

Another Reminder About a Commitment to Compliance

NAVEX on

The U.S. Justice Department has long said (and compliance officers have said it too) that a culture of compliance is what matters in regulatory enforcement actions, and can pay dividends in the form of smaller monetary...more

NAVEX

The Future of U.K. Enforcement of Financial Crimes: Four Clues for 2015

NAVEX on

The legal and compliance landscape is changing quickly—it’s up to organisations that do business in the U.K. to strengthen their compliance programmes to meet these new challenges. In this whitepaper, Andrew Foose, vice...more

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