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Recently issued interpretive guidance from the SEC staff offers some answers for companies that find themselves having to decide whether and when to check one or both of the boxes on Form 10-K related to financial...more
On April 11, 2025, the Staff of the SEC’s Division of Corporation Finance released six Compliance and Disclosure Interpretations (“C&DIs”) that address the Form 10-K restatement checkboxes and related disclosures under Item...more
While the U.S. Department of Justice’s Criminal Division published its fourth version of its “Evaluation of Corporate Compliance Programs (ECCP)” guidance more than six months ago now, the insights that in-house counsel and...more
The U.S. Department of Justice (DOJ) announced Friday a three-year pilot program related to its continued efforts to hold individuals directly accountable for corporate wrongdoing. The two-pronged program incentivizes...more
CEP Magazine - December 2022 - In September, U.S. Department of Justice (DOJ) Deputy Attorney General Lisa O. Monaco announced new guidelines the department will use in connection with criminal enforcement. Those...more
In prepared remarks delivered on Dec. 1, Acting Principal Deputy Assistant Attorney General Nicole Argentieri indicated that the Department is considering new guidance for its revised corporate criminal enforcement policy,...more