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SEC Developments: Strong Enforcement Wake Ahead

Turning a battleship even slightly creates a large wake, not unlike the enforcement waters that have been churning recently at the Securities and Exchange Commission (SEC). The new agency head, Gary Gensler, was formerly an...more

The Evolving Risk of Fraud in the Wake of COVID-19

Earlier this summer, the Department of Justice (DOJ) updated its Evaluation of Corporate Compliance Programs guidance. As the recent updates make clear, one of the hallmarks of an effective corporate compliance program is the...more

DOJ Compliance Guidance Update: Flexibility and Data Centric Programs

Earlier this month, the Department of Justice (DOJ) updated its Evaluation of Corporate Compliance Programs guidance. The updated guidance does not suggest that corporations will be rewarded for deemphasizing or not...more

Congress CARES (Act): Expect Oversight Investigations

Congressional activity is already underway to begin oversight related to the Coronavirus Aid, Relief, and Economic Security (CARES) Act. Based on historical trends and the current political environment, oversight and...more

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