News & Analysis as of

Self-Reporting New Guidance

Eversheds Sutherland (US) LLP

DOJ releases new corporate crime enforcement guidance, telling companies what to expect—and how to avoid criminal penalties

On May 12, 2025, the US Department of Justice’s (DOJ) Criminal Division issued a memorandum titled Focus, Fairness, and Efficiency in the Fight Against White-Collar Crime (the Memo) to all Criminal Division personnel. The...more

WilmerHale

New SFO Guidance Unlikely to Drive Increase in Self-Reporting of Corporate Wrongdoing

WilmerHale on

On April 24, 2025, the UK Serious Fraud Office (SFO) released new guidance to encourage companies to self-report suspected corporate wrongdoing. The guidance emphasises that prompt self-reporting combined with full...more

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

Moore & Van Allen PLLC

The Desk: May Edition

On April 17, 2025, as previewed in the Division of Enforcement’s (“DoE”) February 25, 2025, “Advisory on Self-Reporting, Cooperation, and Remediation”, the Staff of the Market Participants Division (“MPD”) laid the remaining...more

WilmerHale

UK Serious Fraud Office Issues New Self-Reporting and Corporate Cooperation Guidance

WilmerHale on

On 24 April 2025, the UK Serious Fraud Office (SFO) issued new guidance to encourage companies to self-report suspected corporate wrongdoing.  The guidance states that self-reporting, combined with full cooperation with the...more

McDermott Will & Emery

UK Serious Fraud Office Issues Significant New Guidance on Corporate Self-Reporting – What It Means for Your Business

On 24 April 2025, the SFO published new guidance1 for companies in relation to self-reporting, co-operation, and when they can expect to be invited to engage in negotiations for a Deferred Prosecution Agreement (DPA) as an...more

Mayer Brown

Eye on Economic Crime: SFO Releases New Guidance on Corporate Cooperation and Enforcement

Mayer Brown on

On 24 April 2025, the UK’s Serious Fraud Office (“SFO”) launched new guidance for corporates on self-reporting, cooperation and deferred prosecution agreements (“DPAs”). Among other things, the new guidance states that, if a...more

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

Morrison & Foerster LLP

CFTC Advisory Outlines Materiality Criteria for Enforcement Referrals

On April 17, 2025, three operating divisions (the “Operating Divisions”) of the U.S. Commodity Futures Trading Commission (“CFTC”) and the Division of Enforcement (“DOE”) provided guidance in CFTC Letter 25-13 (the...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

BakerHostetler

CFTC Provides Clarifying Guidance on Material Violations Regarding Self-Reporting, Cooperation, and Remediation System

BakerHostetler on

As we previously reported, in February, the CFTC’s DOE issued an enforcement advisory (the DOE Advisory) to provide guidance to market participants on how the DOE will evaluate a company’s or an individual’s conduct in the...more

Jones Day

CFTC Operating and Enforcement Divisions Issue Advisory on Referrals to Enforcement Division

Jones Day on

On April 17, 2025, the Commodity Futures Trading Commission's ("CFTC") operating divisions ("Divisions") provided guidance in an advisory on the criteria they will use when determining whether to refer self-reported...more

Morgan Lewis

CFTC Staff Issue Advisory on Criteria for Referrals to the Division of Enforcement

Morgan Lewis on

The staff of the US Commodity Futures Trading Commission (CFTC or Commission) on April 17, 2025 issued an advisory outlining the criteria the agency’s Market Participants Division, Division of Clearing and Risk, and Division...more

Husch Blackwell LLP

CFTC Releases Criteria for Operating Divisions to Refer Violations to Enforcement Division

Husch Blackwell LLP on

On April 17, 2025, the Commodity Futures Trading Commission’s (CFTC) Market Participants Division (MPD), the Division of Clearing and Risk (DCR), and the Division of Market Oversight (DMO)—collectively the Operating...more

Davis Wright Tremaine LLP

CFTC Divisions Issue Staff Advisory on Referrals to Division of Enforcement

On April 17, 2025, the Market Participants Division, the Division of Clearing and Risk, and the Division of Market Oversight (collectively, the "Operating Divisions") of the CFTC, along with the Division of Enforcement...more

Skadden, Arps, Slate, Meagher & Flom LLP

CFTC Issues Advisory on Referrals to the Division of Enforcement

On April 17, 2025, three operating divisions of the Commodity Futures Trading Commission (CFTC) jointly issued an advisory to provide guidance on the materiality or other criteria they will use in deciding whether to make a...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

Health Care Compliance Association (HCCA)

Compliance should promote the hotline

At a recent HCCA event, large digital signs throughout the conference venue displayed a toll-free number and the message, “If you see something, say something.” The message served as a great reminder that healthcare...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

Health Care Compliance Association (HCCA)

[Event] Regional Compliance & Ethics Conference - February 22nd - 23rd, Anchorage, AK

Looking for compliance education and networking in your area? SCCE & HCCA’s Regional Compliance & Ethics Conferences bring compliance practitioners from all disciplines together for convenient, local compliance education....more

Society of Corporate Compliance and Ethics...

[Event] Regional Compliance & Ethics Conference - February 22nd - 23rd, Anchorage, AK

Looking for compliance education and networking in your area? SCCE & HCCA’s Regional Compliance & Ethics Conferences bring compliance practitioners from all disciplines together for convenient, local compliance education....more

Conn Kavanaugh

“Corporate Citizen, Police Thyself”: How the DOJ Is Changing Its Corporate Enforcement Policy to Encourage Self-Policing

Conn Kavanaugh on

Self-Reporting Remains a Major Focus - Few executives expect to interact with the Department of Justice (DOJ) during their careers, but the current DOJ has given companies some homework, and the assignment applies to...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

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