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Self-Reporting Securities and Exchange Commission (SEC)

Holland & Knight LLP

Buckle Your Seatbelt, It's Going to Be a Bumpy Ride … or Is It?

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Readers, thank you for journeying with us through all nine (and this, our 10th and final!) installments of Season's Readings. In this final piece, we turn from the past and look ahead to what may be in store from the SEC's...more

Holland & Knight LLP

Do You Hear What I Hear? DOJ, SEC Continue Promoting Merits of Self-Reporting in 2024

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2024 saw no change in the government's campaign to encourage self-reporting and cooperation. In the second installment of Season's Readings, we take a quick look at how the SEC treats self-reporting and how that differs...more

Seward & Kissel LLP

Financial Services Firm Affiliates Settle Five SEC Enforcement Actions for Allegedly Misleading Customers and Failing to Act in...

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Who may be interested: Registered Investment Companies; Registered Investment Advisers; Broker Dealers; Compliance Officers; Boards of Directors - Quick Take: The SEC recently settled five separate enforcement proceedings...more

Foley & Lardner LLP

A Review of Recent Whistleblower Developments – Q3 2024

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On August 1, 2024, the Department of Justice (DOJ) launched its Corporate Whistleblower Awards Pilot Program, first announced earlier this year. Through the pilot program, the DOJ may issue awards to whistleblowers who...more

Seward & Kissel LLP

Continued SEC Enforcement Actions Relating to Off Channel Communications

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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

Latham & Watkins LLP

SEC Brings Charges for Failure to File Forms 13F (Investment Manager Share Positions) and 13H (Large Trader Registration)

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The SEC’s September 17, 2024, actions signal its commitment to penalize non-compliance, while encouraging market participants to self-report violations. On September 17, 2024, the US Securities and Exchange Commission...more

The Volkov Law Group

SEC Outlines “Effective Cooperation” Standard

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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

SEC Compliance Consultants, Inc. (SEC³)

Regulatory Roundup for August 2024

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

White & Case LLP

SEC Continues Focus on Off-Channel Communications

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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

Sheppard Mullin Richter & Hampton LLP

Latest Round of SEC “Off-Channel” Communications Settlements Highlights Risks for Investment Advisers and Benefits of...

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

White & Case LLP

DOJ Launches New Whistleblower Pilot Program

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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

Lathrop GPM

DOJ Criminal Division Announces Corporate Whistleblower Awards Pilot Program

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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

BakerHostetler

DOJ Corporate Whistleblower Awards Pilot Program

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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

Womble Bond Dickinson

DOJ Debuts Pilot Corporate Whistleblower Awards Program

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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

Dorsey & Whitney LLP

DOJ’s New Whistleblower Program Incentivizes Individuals and Corporations to Disclose Wrongdoing

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The U.S. Department of Justice (DOJ) just launched the new corporate whistleblower awards pilot program that it previewed this past March. ...more

BCLP

DOJ Piles On the Incentives for Individuals to Blow the Whistle on Companies

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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

Latham & Watkins LLP

DOJ Launches New Whistleblower Incentive Program

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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

Royer Cooper Cohen Braunfeld LLC

Is Your Compliance Program Active or Passive? It Matters.

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

Morrison & Foerster LLP

Top 10 International Anti-Corruption Developments for May 2024

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

White & Case LLP

SEC Enforcement Director Outlines His View of Effective Cooperation

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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

Vinson & Elkins LLP

Securing Integrity: The SEC and DOJ’s Unified Front and Pursuit of Novel Legal Tactics Against Insider Trading and Corporate...

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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

Holland & Knight LLP

Collaboration Station: Director Grewal Touts Benefits and Efficiency of Cooperation

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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

BakerHostetler

SEC Enforcement Director Grewal Doubles Down on Encouraging Self-Reporting

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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

Skadden, Arps, Slate, Meagher & Flom LLP

CFTC Enforcement Director Addresses Self-Reporting Benefits

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

Ogletree, Deakins, Nash, Smoak & Stewart,...

SEC, Federal Regulators Target Employees’ Use of Text Messages, Off-Channel Communications

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

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