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DOJ’s Criminal Division Turns Page on White Collar Crime—But Keeps One Foot in the Past

On May 12, 2025, the DOJ announced a new “white-collar enforcement plan” identifying new corporate enforcement priorities and aiming to promote greater focus, fairness and efficiency in prosecuting corporate misconduct. In a...more

“When you are a hammer, the world is a nail” – SEC and PCAOB Senior Staff Signal Increased SEC and PCAOB Gatekeeper Enforcement

Key Points - SEC Enforcement and PCAOB Enforcement both are pursuing more significant sanctions against auditors, particularly with respect to civil money penalties. Expect 2023 enforcement against auditors to focus...more

Landmark SEC and DOJ Insider Trading Cases Signal Increased Scrutiny of Rule 10b5-1 Plans

Key Points - On March 1, 2023, the SEC and DOJ filed insider trading charges against a public company executive alleging he traded pursuant to 10b5-1 trading plans he adopted while he was in possession of material...more

Navigating the Holding Foreign Companies Accountable Act – The Road to Delisting or Redemption for China-based Companies

Since March, pursuant to the new Holding Foreign Companies Accountable Act (HFCAA), the U.S. Securities and Exchange Commission (SEC) has “identified” more than 135 companies that relied on auditors headquartered in mainland...more

Department of Justice’s 2020 Update Moves the Needle on Guidance for Evaluation of Corporate Compliance Programs

- DOJ’s update offers additional insights into its approach to evaluating corporate compliance programs. - The update places emphasis on compliance programs that are continuously improving, data driven and supported with...more

PCAOB Issues 2019 Staff Inspections Outlook For Audit Committees As Part Of Its Outreach

As part of its transparency and outreach initiative to its stakeholders, the Public Company Accounting Oversight Board (“PCAOB” or “Board”) continues to issue staff briefs to better inform the public about how the Board is...more

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