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DOJ Announces Corporate Compliance Policy Changes and Provides New Guidance on Compensation Clawbacks and Personal Device...

In recent weeks, the U.S. Department of Justice (DOJ) has implemented significant changes to its corporate enforcement policies in an attempt to encourage companies to root out and voluntarily disclose corporate misconduct....more

FINRA Wades into the Controversial Deep-End of CCO Supervisory Liability

The lack of specific guidance regarding failure to supervise liability for chief compliance officers (“CCOs”) has been a controversial and opaque topic that both FINRA and the SEC have struggled with for well over a decade....more

The $180 Million Chinese Coffee Case for Attempting to Manage Earnings

Last week, on December 16, 2020, Chinese-based coffee chain Luckin Coffee Inc. (“Luckin”) agreed to a $180 million settlement with the United States Securities and Exchange Commission (“SEC”). Luckin’s American Depositary...more

SEC Roundtable on Reg BI and Form CRS

The U.S. Securities and Exchange Commission (SEC) hosted a virtual roundtable in late October to discuss the Regulation Best Interest (Reg BI) and Form CRS. With a few months of observations from examinations since the June...more

CFTC Record Enforcement Year and Director Departure

On October 6, 2020, the Commodity Futures Trading Commission (“CFTC”) issued a release describing its record-breaking enforcement year. The release noted that in fiscal year 2020 (“FY2020”), the CFTC filed more enforcement...more

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