News & Analysis as of

Self-Reporting Penalties

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

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

Katten Muchin Rosenman LLP

What the CFTC's Operating Divisions Will Consider When Making Enforcement Referrals

The three operating divisions of the CFTC (Division of Market Oversight, Market Participants Division, and the Division of Clearing and Risk, together the Operating Divisions) issued an advisory on April 17, explaining the...more

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

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

Paul Hastings LLP

CFTC Advisory on Self-Reporting, Cooperation and Remediation: A Game-Changer for the Industry

Paul Hastings LLP on

This week, the CFTC released an Enforcement Advisory setting forth concrete guidelines for self-reporting, cooperation and remediation that will reshape how market participants report and defend potential violations....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

Kilpatrick

8 Key Takeaways | Part Two -- 2024 Roundup: Key Takeaways from U.S. Sanctions Enforcement Actions and 2025 Predictions

Kilpatrick on

Throughout 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control ("OFAC") published 12 enforcement actions regarding alleged sanctions violations by foreign and domestic persons and entities....more

Seward & Kissel LLP

Continued SEC Enforcement Actions Relating to Off Channel Communications

Seward & Kissel LLP on

Who may be interested: Registered Investment Advisers, Registered Investment Companies, Compliance Staff - Quick Take: The SEC recently announced a number of additional enforcement actions relating to recordkeeping...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

CFTC Issues New Enforcement Advisory on Penalties, Monitors and Admissions

On October 17, 2023, the Division of Enforcement (the Division) of the Commodity Futures Trading Commission (CFTC or the Commission) issued an advisory to Division staff providing guidance on what recommendations the Division...more

Seward & Kissel LLP

SEC Charges 11 Firms with Widespread Recordkeeping Failures

Seward & Kissel LLP on

Who may be interested: Registered Investment Advisers, Broker-Dealers, Registered Investment Companies, Boards of Directors - Quick Take: The SEC recently settled charges against ten broker-dealers and one dually...more

Venable LLP

Honesty is Good for Your Bottom Line: Commerce, Treasury, and DOJ Tout the Benefits of Voluntary Self Disclosure in Tri-Seal...

Venable LLP on

Voluntary self-disclosure is a valuable remediation measure for companies who identify their own potential violations of U.S. sanctions, export controls, and other national security laws....more

Bass, Berry & Sims PLC

Failure to Voluntarily Self-Report is a "Non-starter" under the FCA

Bass, Berry & Sims PLC on

On July 5, 2019, the D.C. Circuit Court of Appeals affirmed dismissal of a qui tam lawsuit against several chemical manufacturers that set forth a unusual theory of liability: the relator alleged that the manufacturers...more

Ballard Spahr LLP

MDE Self-Disclosure Can Limit, Even Eliminate Risk of Environmental Penalties

Ballard Spahr LLP on

Maryland entities that voluntarily discover and disclose environmental violations can still receive penalty reductions, or even complete forgiveness, under the rarely invoked Maryland Department of the Environment (MDE)...more

Best Best & Krieger LLP

Best in Law: Get Out in Front on Possible Environmental Violations

It’s no secret that businesses must run a gauntlet of federal, state and local environmental regulations in order to successfully operate in California. But the hardest test may be when a business suspects that it may be...more

Davis Wright Tremaine LLP

EPA’s Audit Policy eDisclosure: Electronic Self-Reporting for Environmental Violations

Reporting uner EPA’s audit policy, which has provided relief from gravity-based penalties to those who self-report, is about to become much easier. This fall, EPA expects to launch a centralized web-based “eDisclosure” portal...more

JAMS

Corruption in The Energy Sector: Criminal Fines, Civil Judgments, And Lost Arbitrations

JAMS on

Synopsis - This article examines the anti-bribery legislation of three countries, the United States, Canada, and the United Kingdom. The legislation of the three countries is compared and virtually all the criminal...more

19 Results
 / 
View per page
Page: of 1

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
- hide
- hide