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Clearer Carrots and More Restrained Sticks: Key Updates to DOJ Corporate Enforcement Policies

“The Criminal Division is turning a new page on white-collar and corporate enforcement.” So pronounced the head of the US Department of Justice (DOJ) Criminal Division, Matthew Galeotti, in a recent speech rolling out several...more

Asset Management Regulatory Year in Review 2024

2024 was a year of meaningful regulatory change for asset managers globally. The regulatory activity was wide ranging and without a particular unifying theme. In fact, the wide, and in cases diverging focuses of key global...more

FERC Issues 2023 Enforcement Report

On 16 November 2023, the Federal Energy Regulatory Commission’s (FERC or Commission) Office of Enforcement (Enforcement) released its 2023 Annual Report on Enforcement (FY2023 Report). The FY2023 Report is the 8th annual...more

Recent Settlements Provide Insight on the SEC's Approach to Self-Reporting and Cooperation Credit in Enforcement Actions

Introduction - A perennial message from the Securities and Exchange Commission (SEC) Division of Enforcement is to extol the benefits of cooperation with enforcement investigations. The link between cooperation and a...more

FERC Approves Enforcement's Settlements With Two Demand Response Providers

On 22 May 2023, the Federal Energy Regulatory Commission (FERC) issued two orders approving stipulation and consent agreements that resolve enforcement investigations by FERC’s Office of Enforcement (FERC Enforcement) of two...more

Supreme Court Wades Into Circuit Split, Endorses Broader View of "Scheme Liability" for Disseminating False Statements

On Wednesday, March 27, 2019, the U.S. Supreme Court ruled in favor of the Securities and Exchange Commission (“SEC”) and endorsed a broad view of so-called “scheme liability” under SEC Rule 10b-5(a) and (c)....more

A New Cyber Regulator on the Beat: The CFPB Issues its First Cybersecurity Order and Fine

On March 2, 2016, the Consumer Financial Protection Bureau (“CFPB”) instituted its first data security enforcement action, in the form of a consent order against online payment platform Dwolla, Inc....more

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