Last week, the SEC announced settled charges against 23 companies and individuals for failing to timely file Section 16 reports on Forms 3, 4 or 5.
Additionally, two public companies were charged for contributing to late...more
10/4/2024
/ Analytics ,
Corporate Governance ,
Enforcement Actions ,
Failure To Disclose ,
Filing Deadlines ,
Filing Requirements ,
Neither Admit Nor Deny Settlements ,
Publicly-Traded Companies ,
Required Forms ,
Securities and Exchange Commission (SEC) ,
Statutory Penalties
In June, the U.S. Department of Justice updated its Evaluation of Corporate Compliance Programs Guidance (“Guidance”). While the Guidance is intended to assist prosecutors by providing factors to consider in evaluating the...more
In September 1998, U.S. SEC Chairman Arthur Levitt gave a speech called, “The Numbers Game” in which he expressed his “fear that we are witnessing an erosion in the quality of earnings, and therefore, the quality of financial...more
Under the Senior Managers and Certification Regime (“SMCR”), firms are required to identify and report to the FCA any instances of disciplinary action taken in relation to conduct that would amount to a breach of one of the...more
2/10/2020
/ Artificial Intelligence ,
Banking Sector ,
Blockchain ,
Bribery ,
Cartels ,
Corporate Governance ,
Corporate Misconduct ,
Environmental Social & Governance (ESG) ,
EU ,
Financial Conduct Authority (FCA) ,
Financial Institutions ,
Financial Services Industry ,
Hong Kong Securities and Futures Commission (HKSFC) ,
Insurance Industry ,
Payment Systems ,
Risk Management ,
SMCR ,
Technology ,
UK ,
United Arab Emirates (UAE) ,
Whistleblower Protection Policies
Multiple news items published over the past six weeks (including as recently as January 30, 2020) have focused on public companies’ correction of accounting errors by revising their financial statements, rather than doing so...more
No matter the industry, maintaining effective corporate compliance programs has never been a more essential part of operations to address the legal risks that corporates face. This article, the third in a series about...more
5/22/2018
/ Chief Compliance Officers ,
Compliance ,
Corporate Governance ,
Deferred Prosecution Agreements ,
Department of Justice (DOJ) ,
France ,
Non-Prosecution Agreements ,
Risk Assessment ,
Risk Management ,
Sapin II ,
Serious Fraud Office (SFO) ,
UK
Enforcement of the Foreign Corrupt Practices Act (FCPA) again remained a high priority for the Department of Justice and the Securities and Exchange Commission in 2017, resulting in 11 companies paying over $1.92 billion to...more
2/9/2018
/ Chief Compliance Officers ,
Compliance ,
Corporate Governance ,
Department of Justice (DOJ) ,
Enforcement ,
Enforcement Actions ,
Enforcement Authority ,
Facilitation Payments ,
Foreign Corrupt Practices Act (FCPA) ,
State-Owned Enterprises ,
Successor Liability