News & Analysis as of

Self-Reporting Enforcement Actions Corporate Misconduct

Alston & Bird

Carrots and Sticks Cross the Pond: The SFO’s New Corporate Self-Reporting and Cooperation Guidance

Alston & Bird on

The UK Serious Fraud Office (SFO) has issued new guidance to encourage companies to self-report suspected corporate criminal conduct and cooperate fully with investigations. Our transatlantic White Collar, Government &...more

Hogan Lovells

SFO's new self-reporting guidance: A new deal or a departure from justice?

Hogan Lovells on

On 24 April 2025, the Serious Fraud Office (SFO) issued new guidance signalling a notable shift in its approach to corporate criminal enforcement. For the first time, the SFO has stated that if a company self-reports...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

Vinson & Elkins LLP

To Self-Report or Not to Self-Report: With New M&A Safe Harbor Policy, DOJ Tries to Answer the Question

Vinson & Elkins LLP on

It is one of the hardest questions a company can face: after discovering criminal conduct inside your company, do you self-report to the government or not? If you can quickly and quietly fix the problem, then you may be able...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

McDermott Will & Emery

DOJ Announces Major Changes to Corporate Compliance Program Evaluation Criteria

During speeches on March 2 and 3, 2023, at the American Bar Association (ABA) National Institute on White Collar Crime (the 2023 White Collar Conference), Deputy Attorney General (DAG) Lisa Monaco, Assistant Attorney General...more

Arnall Golden Gregory LLP

New DOJ Corporate Enforcement Policy Places Still More Pressure on Companies to Cooperate and Self-Report

Last month in a speech at Georgetown University Law Center, Assistant Attorney General Kenneth A. Polite, Jr., announced revisions to the Department of Justice’s Corporate Enforcement Policy, to apply to all corporate...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

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

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

BakerHostetler

CFTC Joins Other Federal Agencies in Issuing Guidance to Make Transparent Certain Guideposts When Contemplating an Enforcement...

BakerHostetler on

On September 10, 2020, the Commodity Futures Trading Commission (CFTC or Commission) announced the issuance of new, public, staff-level guidance by its Division of Enforcement (Division) that outlines factors to be considered...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

Proskauer - Whistleblower Defense

SEC Awards Whistleblower More Than $4.5 Million

On May 24, 2019, the SEC announced payment of more than $4.5 million to a whistleblower who sent an anonymous tip to the company alleging significant wrongdoing and then submitted the same information to the SEC....more

Stinson - Corporate & Securities Law Blog

SEC Awards First Ever $4.5 Million to Internal Whistleblower

The SEC awarded more than $4.5 million to a whistleblower whose tip triggered the company to review the allegations as part of an internal investigation and subsequently report the whistleblower’s allegations to the SEC and...more

Jones Day

CFTC Issues Advisory on Self-Reporting of Foreign Corrupt Practices for Non-Registrants

Jones Day on

The Advisory is part of the agency's broader commitment to provide "incentives for companies and individuals to engage in ethical corporate behavior." On March 6, 2019, the U.S. Commodity Futures Trading Commission...more

Stinson - Corporate & Securities Law Blog

CFTC Issues Advisory on Violations of the Commodity Exchange Act Involving Foreign Corrupt Practices

The CFTC announced an Enforcement Advisory on self-reporting and cooperation for violations of the Commodity Exchange Act, or CEA, involving foreign corrupt practices. ...more

Hogan Lovells

The lesser spotted, greatly discussed DPA

Hogan Lovells on

On 19 March 2018, Singapore's Parliament ushered in a raft of criminal justice reforms, including the significant introduction of a deferred prosecution agreement ("DPA") regime. ...more

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