News & Analysis as of

Self-Reporting Enforcement Actions Remediation

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

Jones Day

New CFTC Cooperation, Self-Reporting, and Remediation Enforcement Advisory Introduces Major Changes

Jones Day on

The Commodity Futures Trading Commission's ("CFTC") new enforcement advisory introduces several major changes in policy and a matrix helping those facing potential or actual CFTC investigations quantify the extent to which...more

Bracewell LLP

The CFTC’s New Advisory on Self-Reporting, Cooperation and Remediation

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In an advisory announced February 25, 2025, the Division of Enforcement of the Commodity Futures Trading Commission (CFTC or Commission) announced a new regime for assessing cooperation credit in determining fines in the...more

Husch Blackwell LLP

CFTC Enforcement Division Releases Mitigation Credit Matrix for Self-Reporting, Cooperation, and Remediation

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On February 25, 2025, the Commodity Futures Trading Commission (CFTC) signaled a shift in its enforcement approach by releasing new guidance on the role self-reporting and cooperation play in its assessment of penalties. The...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

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

Jenner & Block

Client Alert: How Regulatory Events of 2023 Should Guide Financial Institutions' New Year's Resolutions for 2024

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As consumer-facing financial institutions of all types—from well-established banks to newly-launched fintechs—set their 2024 regulatory compliance goals, they may wonder if their New Year’s resolutions align with those that...more

Holland & Knight LLP

Twinkle-Twinkle Little SAR: SEC & FINRA Settle with Broker-Dealers and Registered Rep

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In a series of settlements announced this year, the U.S. Securities and Exchange Commission (SEC) and the Financial Industry Regulatory Authority (FINRA) penalized several broker-dealers for allegedly failing to file...more

Society of Corporate Compliance and Ethics...

[Virtual Event] Corporate Compliance Enforcement Conference - July 25th, 9:00 am - 4:45 pm CT

Is Your Compliance Program Designed for the Current Enforcement Landscape? Data protection, anti-corruption, antitrust, supply chains, economic sanctions and even the software employees use to communicate are all subjects...more

Society of Corporate Compliance and Ethics...

What do you mean, "cooperate"?

CEP Magazine (September 2022) - This month’s column is about something I hope you never have to address: cooperating with government officials in connection with an investigation into a compliance violation at your...more

Society of Corporate Compliance and Ethics...

Compliance Perspectives: The Antitrust Division’s Office of Decree Enforcement

The approach to compliance programs of the Antitrust Division at the US Department of Justice has evolved considerably over the last few years, starting with the release of their watershed Evaluation of Corporate Compliance...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

Vinson & Elkins LLP

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

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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

Troutman Pepper Locke

Investment Management Roundtable Discussion – Regulatory and Enforcement Update

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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

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

Vedder Price

DOJ Criminal Division Announces Major Change in Corporate Enforcement Policy

Vedder Price on

On March 1, 2018, the Criminal Division of the U.S. Department of Justice (“DOJ”) announced that it has expanded the scope of cases in which it will consider issuing a formal declination of criminal charges for a company that...more

Bracewell LLP

DOJ Issues New Policy Encouraging Self-Reporting FCPA Violations

Bracewell LLP on

On November 29, 2017 the Deputy Attorney General of the U.S. Department of Justice (DOJ), Rod J. Rosenstein, announced a new FCPA enforcement policy that seeks to incentivize voluntary self-reporting by providing companies...more

Bradley Arant Boult Cummings LLP

DOJ’s FCPA Corporate Enforcement Policy Creates Greater Certainty for Companies

The Foreign Corrupt Practices Act of 1977 (FCPA) makes it unlawful for certain classes of persons and entities to make payments to foreign government officials to assist in obtaining or retaining business. On November 29,...more

Jones Day

DOJ's New FCPA Enforcement Policy Continues its "Carrot-and-Stick" Approach

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The Situation: Companies that learn of Foreign Corrupt Practices Act ("FCPA") violations by employees or agents are faced with significant uncertainty as to whether the benefits and risks of self-disclosing the conduct to the...more

Dorsey & Whitney LLP

Dorsey Anti-Corruption Digest - April 2016

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Welcome to Dorsey & Whitney’s monthly Anti-Corruption Digest. In this digest, we draw together news of enforcement activity throughout the world and aim to reduce your information overload. Our London, Minneapolis, New York...more

Thomas Fox - Compliance Evangelist

FCPA Compliance and Ethics Report-Episode 31-the FCPA Year in Review, Corporate Enforcement Actions

In this episode, I review the corporate FCPA enforcement actions of 2013. ...more

Morrison & Foerster LLP

How to Be a Good Corporate Citizen CFPB Style

On June 25, 2013, the Consumer Financial Protection Bureau (CFPB) issued Bulletin 2013-06 identifying “responsible business conduct” that may impact the exercise of its “enforcement discretion.” The Bulletin specifies the...more

Stinson - Corporate & Securities Law Blog

CFPB Encourages Self-Policing And Self-Reporting

The CFPB has issued a bulletin encouraging self-policing, self-reporting, remediation, and cooperation....more

Davis Wright Tremaine LLP

“Responsible Conduct” by Enforcement Targets May Justify Favorable Treatment

Earlier this week, the Consumer Financial Protection Bureau (CFPB) issued CFPB Bulletin 2013-06 (the Bulletin), entitled Responsible Business Conduct: Self-Policing, Self-Reporting, Remediation, and Cooperation....more

Ballard Spahr LLP

CFPB issues guidance on “responsible conduct” that can result in enforcement leniency

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A new CFPB Bulletin provides guidance on “responsible conduct” the CFPB will consider in deciding how to exercise its enforcement discretion....more

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