Corruption, Crime & Compliance: DOJ’s Shifting Approach to Recidivism and Self-Disclosure
Encouraging and Managing Employee Self-Reporting
The Latest on Antitrust Compliance
Andy Dunbar and Nick Morgan on What the SEC Expects from Your Internal Investigation
Compliance Perspectives: The Antitrust Division’s Office of Decree Enforcement
FERC: A Discussion on its Mission, Market Manipulation Investigations, and Common Violations
Investment Management Roundtable Discussion – Regulatory and Enforcement Update
Podcast - Risk Management: Impact of Revised FCPA Policy on International Risk Management Programs
FCPA Compliance and Ethics Report-Episode 380, Laura Perkins on issues around self-disclosure
Nonpayment of Subcontractors: Can Subcontractors Get Any Help From the Government?
Episode 155-Mara Senn on FCPA Investigations and the Decision to Self-Disclose
FCPA Compliance and Ethics Report-Episode 31-the FCPA Year in Review, Corporate Enforcement Actions
Corporate Criminal Liability – Interview with Bridget Rohde, Member, Mintz Levin
The Securities and Exchange Commission is catching up to DOJ. Not in enforcement but in transparency. After years of criticism, the Justice Department has set the gold standard for transparency and providing guidance on...more
More Flack on WhatsApp, Hypothetical Performance SmackDown, A Timely Warning on the Pay-to-Play Rule, and Updates to Qualifying Venture Capital Fund Exemption - This month's big news from the SEC was more piggy-bank breaking...more
On August 14, the U.S. Securities and Exchange Commission (“SEC”) announced yet another wave of enforcement actions related to widespread “off-channel communications,” charging an additional 26 firms with failing to maintain...more
More than two years after announcing the first round of settlements in the ongoing “off-channel communications” probe, the SEC recently announced another round of settlements with 26 financial firms, totaling $390 million in...more
In March 2024, we published an alert regarding Deputy Attorney General (“DAG”) Lisa Monaco’s announcement that the US Department of Justice (“DOJ” or the “Department”) intended to design and implement a new whistleblower...more
In her remarks to the American Bar Association’s National Institute on White Collar Crime, Deputy Attorney General (DAG) Lisa Monaco outlined the forthcoming whistleblower program that seeks to fill in the gaps of existing...more
DOJ has introduced the new three-year Pilot Program, managed by the Criminal Division’s Money Laundering and Asset Recovery Section, effective August 1. Under this Pilot Program, whistleblowers meeting certain criteria may be...more
The U.S. Department of Justice’s (“DOJ”) Criminal Division announced its new Corporate Whistleblower Awards Pilot Program on August 1, 2024. The Pilot Program incentivizes whistleblowers to provide information to the DOJ so...more
The U.S. Department of Justice (DOJ) just launched the new corporate whistleblower awards pilot program that it previewed this past March. ...more
Historically, successful white-collar prosecutions often turn on the government’s ability to identify “insiders” with firsthand knowledge of the alleged criminal scheme, who opt to cooperate with prosecutors in exchange for...more
DOJ’s pilot program aims to fill gaps in existing federal whistleblower programs and incentivize prompt corporate self-disclosure alongside individual whistleblower tips. Following the March 2024 announcement of its...more
The SEC's Director of the Division of Enforcement, Gurbir S. Grewal, outlined five principles of effective cooperation with the SEC during his keynote address at the Securities Enforcement Forum West 2024 conference...more
Designed for busy in-house counsel, compliance professionals, and anti-corruption lawyers, this newsletter summarizes some of the most important international anti-corruption law and enforcement developments from the past...more
In February 2024, we published an alert discussing the significant benefits of prompt self-reporting and cooperation during a US Securities and Exchange Commission ("SEC") investigation. This past week, during his keynote...more
The U.S. Securities and Exchange Commission (“SEC”) and Department of Justice (“DOJ”) have been working increasingly collaboratively to combat unlawful trading practices and hold wrongdoers accountable, demonstrating...more
In recent remarks at the Securities Enforcement Forum West 2024, U.S. Securities and Exchange Commission (SEC) Director of the Division of Enforcement Gurbir Grewal extolled the benefits of and expounded on the elements of...more
In a recent interview with Law360, Securities and Exchange Commission (SEC) Enforcement Director Gurbir Grewal reiterated the agency’s commitment to the encouragement of voluntary self-reporting, going as far as to say that...more
On April 11, 2024, Ian McGinley, the director of enforcement at the Commodity Futures Trading Commission (CFTC) addressed the New York City Bar Association Futures and Derivatives Committee to present the benefits of...more
The U.S. Securities and Exchange Commission (SEC) and other financial regulators are targeting regulated entities over their employees’ use of personal messaging apps and other off-channel electronic communication platforms,...more
Recently, a senior officer from the SEC's Division of Enforcement defended the penalties the Commission has levied on firms for failing to capture and retain their employees' "off-channel" electronic communications, and, in...more
In early March 2024 at the American Bar Association’s 39th National Institute on White Collar Crime, Deputy Attorney General (DAG) Lisa Monaco’s keynote remarks previewed the development of new and significant Department of...more
On March 7, 2024, Deputy Attorney General Lisa Monaco said that the U.S. Department of Justice (DOJ) will test out a program to pay whistleblowers if they provide information on serious financial crimes and foreign and...more
Among the worst nightmares of public company executives may be reports of possible accounting errors in earlier periodic filings or alleged employee manipulation of numbers. What to do? The historical playbook is well known....more
On February 6, 2023, the US Securities and Exchange Commission ("SEC") announced that it settled accounting fraud charges against Cloopen Group Holding Limited ("Cloopen" or the "Company"), a cloud-based communications...more
Publicly announced Foreign Corrupt Practices Act (FCPA) enforcement activity in 2023 did not return to the levels seen a few years ago, as indicated by both the total number of cases against corporate and individual...more