News & Analysis as of

Enforcement Guidance Civil Monetary Penalty

BakerHostetler

The CFTC Announces a New System To Incentivize Self-Reporting, Cooperation, and Remediation

BakerHostetler on

On February 25, 2025, the CFTC released an Enforcement Advisory on Self-Reporting, Cooperation, and Remediation, introducing metrics the Division will use to evaluate a company’s or individual’s conduct before and leading up...more

Jones Day

Minor Revolution at the CFTC: New Enforcement Guidance Will Sharpen Settlement Terms

Jones Day on

The Background: The CFTC Division of Enforcement ("Enforcement") recently issued an advisory on new enforcement policies that increase the agency's focus on corporate accountability through increasing civil penalties,...more

Littler

SEC Continues to Attack Non-Disclosure Agreements and Personnel Policy Provisions that Could Impede Employees from Reporting...

Littler on

The SEC continues to review non-disclosure agreements and other confidential business information provisions of publicly traded companies to ensure whistleblowers are not restricted from freely communicating with the agency...more

BCLP

Observations from a Review of FINRA’s 2021 Sanction Guidelines

BCLP on

Key Takeaways: ..FINRA released its most recent Sanctions Guideline, effective immediately, on October 20, 2021. A link to that document can be found here. ..The key change in the 2021 Sanctions Guideline is a new...more

Orrick, Herrington & Sutcliffe LLP

CFTC Enforcement Announces a Record Year

The CFTC’s Division of Enforcement (the “Division”) released its Annual Report on December 1, 2020, which provides insights into the Division’s priorities in both the prior and coming years.  ...more

Bass, Berry & Sims PLC

U.S. District Court Deals Rare Defeat to OFAC in U.S. Sanctions Matter

Bass, Berry & Sims PLC on

• $2 million penalty against Exxon overturned • Court concluded that OFAC failed to provide clear notice of violative conduct • Companies are at risk when acting in context of ambiguous agency guidance At the end of...more

Katten Muchin Rosenman LLP

Bridging The Week - October 2019 #2

A broker-dealer and its chief executive officer settled charges brought in 2017 by the Securities and Exchange Commission that the firm facilitated manipulative conduct by a customer, despite being alerted by regulators and...more

The Volkov Law Group

OFAC Joins the Compliance Club – Issues Framework for Sanctions Compliance Programs (Part I of IV)

The Volkov Law Group on

On the heels of the Justice Department’s announcement of its new compliance guidance, on May 2, 2019, the Treasury Department’s Office of Foreign Asset Control (“OFAC”) issued its promised guidance for sanctions compliance...more

Morgan Lewis

NYC Commission on Human Rights Releases Interpretive Enforcement Guide for the SCDEA

Morgan Lewis on

The Commission’s guide outlines narrow interpretation and recordkeeping requirements for employers seeking exemptions to the SCDEA, as well as guidance on enforcement and penalties for SCDEA violations....more

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