News & Analysis as of

Cooperation Enforcement Actions

Womble Bond Dickinson

The ICO’s Penalty Against 23andMe Brings New Emphasis on Cybersecurity Risks - Key Takeaways for U.S. Companies

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The dramatic increase in global reach that the internet provides U.S.-based companies comes as a double edge sword. While it significantly increases a company’s potential customer pool, it also subjects companies to...more

Thomas Fox - Compliance Evangelist

All Things Investigations: Navigating New DOJ Directives - Declinations, Cooperation, and Whistleblower Programs with Mike...

Welcome to the Hughes Hubbard Anti-Corruption & Internal Investigations Practice Group’s podcast, All Things Investigation. In this podcast, host Tom Fox is joined by HHR lawyers Mike DeBernardis and Katherine Taylor about...more

Morrison & Foerster LLP

UK Serious Fraud Office Issues New Guidance on Corporate Cooperation and Enforcement

On 24 April 2025, the UK’s Serious Fraud Office (SFO) published new guidance for companies on cooperation and enforcement in relation to corporate criminal offending (Guidance). The Guidance outlines the SFO’s key...more

Skadden, Arps, Slate, Meagher & Flom LLP

CFTC Director of Enforcement Provides Insight on Recent Advisory

On March 27, 2025, the Futures Industry Association hosted a webinar with Brian Young, the director of the U.S. Commodity Futures Trading Commission (CFTC) Division of Enforcement. Although he noted that the opinions...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

CFTC Unveils Replacement Penalty Mitigation Policy Focused on Self-Reporting, Cooperation, and Remediation

The Commodity Futures Trading Commission (CFTC), an independent U.S. government agency that regulates the U.S. derivatives markets, including futures, options, and swaps, has announced a new policy for mitigating potential...more

Jenner & Block

Client Alert: CFTC Issues New Enforcement Advisory Aiming to Incentivize Self-Reporting and Cooperation

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On February 25, 2025, the Division of Enforcement (the “Division”) of the Commodity Futures Trading Commission (the “CFTC” or “Commission”) issued an Enforcement Advisory which quantifies the monetary credit that entities can...more

Jones Day

New CFTC Cooperation, Self-Reporting, and Remediation Enforcement Advisory Introduces Major Changes

Jones Day on

The Commodity Futures Trading Commission's ("CFTC") new enforcement advisory introduces several major changes in policy and a matrix helping those facing potential or actual CFTC investigations quantify the extent to which...more

Bracewell LLP

The CFTC’s New Advisory on Self-Reporting, Cooperation and Remediation

Bracewell LLP on

In an advisory announced February 25, 2025, the Division of Enforcement of the Commodity Futures Trading Commission (CFTC or Commission) announced a new regime for assessing cooperation credit in determining fines in the...more

Baker Botts L.L.P.

CFTC Issues Enforcement Advisory Adopting New Approach for Consideration of Self-Reporting, Cooperation, and Remediation

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On February 25th, the Commodity Futures Trading Commission (CFTC or Commission) adopted a new approach for how the Division of Enforcement (Division) will assess self-reporting, cooperation, and remediation efforts when...more

Holland & Knight LLP

Fashion Retailer Failed to "Express" $1M in Perks But Skirts Civil Penalties

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Like a fashion trend that never fails to come back in style (we look fabulous in baggy jeans, btw), we're revisiting SEC enforcement actions involving public company executive perquisites – or "perks" – a topic we have...more

Society of Corporate Compliance and Ethics...

Understanding the Latest DOJ Changes to Corporate Prosecutions

On November 22, 2024, then Principal Deputy Assistant Attorney General Nicole Argentieri recapped the changes made during the Biden Administration in enforcement policies and announced a few new ones. To better understand...more

Whiteford

Client Alert: FTX Fraud Case Highlights Risks and Rewards of Cooperation in Crypto Cases

Whiteford on

The recent sentencing of Zixiao "Gary" Wang, a tech expert involved in the $11 billion FTX fraud, underscores the importance of cooperation with authorities in complex and high-stakes crypto cases. Wang, who admitted to...more

Latham & Watkins LLP

SEC Brings Charges for Failure to File Forms 13F (Investment Manager Share Positions) and 13H (Large Trader Registration)

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The SEC’s September 17, 2024, actions signal its commitment to penalize non-compliance, while encouraging market participants to self-report violations. On September 17, 2024, the US Securities and Exchange Commission...more

BCLP

SEC Penalizes Company for "Unsupported Hype"

BCLP on

The SEC announced settled charges against Zymergen Inc. in connection with its IPO based on misleading statements about its market potential, revenue prospects and customer pipeline. After raising $530 million in the 2021...more

Holland & Knight LLP

Modificación del régimen sancionatorio ambiental en Colombia

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Hay siete novedades relevantes que las empresas en Colombia deben tener en cuenta con ocasión de la sanción de la Ley 2387 del 25 de julio de 2024, que modifica el régimen sancionatorio ambiental contenido en la Ley 1333 de...more

Husch Blackwell LLP

The Justice Insiders Podcast - AI-Washing: Everything Old Is New Again

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Host Gregg N. Sofer welcomes Husch Blackwell attorney Rebecca Furdek back to the show to discuss recent government inquiries and enforcement actions concerning products and services related to artificial intelligence (AI)....more

Latham & Watkins LLP

10 Key Takeaways Developments in International Cartel Enforcement and Observations From Workshop

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Latham’s Antitrust & Competition Practice provides insight on the current state of enforcement, including more expansive views of what constitutes a cartel, enhanced detection tools, and what to expect next....more

White & Case LLP

SEC Enforcement Director Outlines His View of Effective Cooperation

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In February 2024, we published an alert discussing the significant benefits of prompt self-reporting and cooperation during a US Securities and Exchange Commission ("SEC") investigation. This past week, during his keynote...more

Nutter McClennen & Fish LLP

Nutter Securities Enforcement Update: April 18, 2024

The Nutter Securities Enforcement Update is a periodic update of noteworthy recent securities enforcement activity, settlements, decisions, and charges. We provide brief summaries that highlight recent enforcement action...more

Goodwin

SEC Speaks Conference 2024

Goodwin on

The SEC (U.S. Securities and Exchange Commission) recently hosted the 2024 SEC Speaks conference in Washington, DC. During the event, SEC leaders, including the Chair, commissioners, and senior staffers, shared their views...more

BCLP

CFTC’s Annual Enforcement Results: Another Blockbuster Year

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The Commodity Futures Trading Commission ("CFTC") recently released its enforcement results for Fiscal Year 2023 ("FY 2023"), which ran from October 1, 2022, through September 30, 2023. ...more

BCLP

Caught in the crosshairs: How the PRA’s new Early Account Scheme impacts individuals

BCLP on

The Prudential Regulation Authority (“PRA”) has kicked-off 2024 by crystallising its new approach to enforcement. The key change is the introduction of the Early Account Scheme (“EAS”), which provides a mechanism for the...more

Littler

DHS Announces Special Immigration Protection for Workers Who Help in Labor and Employment Agency Investigations

Littler on

The Department of Homeland Security (DHS) has recently announced a streamlined process for foreign workers to request deferred action. Deferred action is a type of prosecutorial discretion to defer removal action...more

WilmerHale

Global Anti-Bribery Year-in-Review: 2023 Developments and Predictions for 2024

WilmerHale on

Publicly announced Foreign Corrupt Practices Act (FCPA) enforcement activity in 2023 did not return to the levels seen a few years ago, as indicated by both the total number of cases against corporate and individual...more

Cornerstone Research

SEC Cryptocurrency Enforcement Report Summary

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Cryptocurrency enforcement continues to be a high priority for the U.S. Securities and Exchange Commission (SEC). In 2023, the SEC administration under Chair Gary Gensler brought a total of 46 cryptocurrency-related...more

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