The U.S. Department of Justice (DOJ or Department) announced on May 12, 2025, new investigative and policy priorities, as well as changes to current DOJ guidance, that could have a significant impact on the prosecution of...more
5/15/2025
/ Anti-Money Laundering ,
China ,
Cooperation ,
Corporate Misconduct ,
Department of Justice (DOJ) ,
Enforcement Priorities ,
Financial Crimes ,
Healthcare Fraud ,
New Guidance ,
Non-Prosecution Agreements ,
Significant Transnational Criminal Organization ,
Voluntary Disclosure ,
Whistleblowers ,
White Collar Crimes
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
Whistleblower programs are the gifts that keep giving to enforcement agencies, driving a record number of cases, sanctions and awards across multiple agencies. In this ninth installment of Season's Readings, we revisit some...more
12/20/2024
/ Appointments Clause ,
Article II ,
CFTC ,
Compliance ,
Corporate Misconduct ,
Corruption ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Enforcement Priorities ,
Enforcement Statistics ,
False Claims Act (FCA) ,
Federal Pilot Programs ,
FinCEN ,
Securities and Exchange Commission (SEC) ,
Whistleblower Awards ,
Whistleblower Protection Policies ,
Whistleblowers ,
White Collar Crimes
The number of Foreign Corrupt Practices Act (FCPA)-related actions the SEC and U.S. Department of Justice (DOJ) reported in 2024 reflects that these cases remain a priority for both agencies. However, DOJ took the lead over...more
12/13/2024
/ Anti-Money Laundering ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Enforcement Authority ,
Enforcement Statistics ,
Federal Pilot Programs ,
FEPA ,
Foreign Corrupt Practices Act (FCPA) ,
Qui Tam ,
Securities and Exchange Commission (SEC) ,
Whistleblowers
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
The SEC's Division of Enforcement recently announced its Fiscal Year (FY) 2023 results, touting a record-setting year. Rather than repeat Enforcement's detailed report available here, we boil the data down to give our readers...more
11/21/2023
/ Civil Monetary Penalty ,
Cooperation ,
Cryptoassets ,
Cybersecurity ,
Disgorgement ,
Enforcement Actions ,
Enforcement Statistics ,
Environmental Social & Governance (ESG) ,
Publicly-Traded Companies ,
Securities and Exchange Commission (SEC) ,
Whistleblower Awards ,
Whistleblowers
As the SEC closed its fiscal year, it filed three separate enforcement actions against companies for purported violations of Rule 21F-17 under the Securities and Exchange Act of 1934, which prohibits persons from impeding...more
10/10/2023
/ Civil Monetary Penalty ,
Compliance ,
Contract Terms ,
Employment Contract ,
Enforcement Actions ,
Policies and Procedures ,
Remediation ,
Retaliation ,
Rule 21F-17 ,
Securities and Exchange Commission (SEC) ,
Securities Exchange Act ,
Securities Violations ,
Separation Agreement ,
Whistleblower Protection Policies ,
Whistleblowers
Section 21F, titled "Whistleblower Incentives and Protection," is a set of provisions within the Securities Exchange Act of 1934 that govern, among other things, the rights and obligations of SEC whistleblowers and the...more
"Record breaking" is how the U.S. Securities and Exchange Commission (SEC) described its whistleblower program results in FY 2021, and it's not hard to see why. The agency continued to receive tips from all corners of the...more
1/27/2022
/ Anti-Retaliation Provisions ,
Department of Justice (DOJ) ,
Dodd-Frank ,
Enforcement ,
Financial Statements ,
Market Manipulation ,
Securities ,
Securities and Exchange Commission (SEC) ,
Securities Exchange Act of 1934 ,
Whistleblower Protection Policies ,
Whistleblowers
The U.S. Securities and Exchange Commission's (SEC) Division of Enforcement (Division) published its Annual Report for Fiscal Year 2021 on Nov. 18, 2021. The Annual Report – the first issued under new Enforcement Director...more
12/1/2021
/ Annual Reports ,
Compliance ,
Department of Justice (DOJ) ,
Disgorgement ,
Enforcement Actions ,
Enforcement Statistics ,
Environmental Social & Governance (ESG) ,
Foreign Corrupt Practices Act (FCPA) ,
Securities and Exchange Commission (SEC) ,
Special Purpose Acquisition Companies (SPACs) ,
Whistleblower Awards ,
Whistleblowers