News & Analysis as of

Executive Compensation Enforcement Actions

Keating Muething & Klekamp PLL

Securities Snapshot: 2nd Quarter 2025

AI Claims, Executive Pay, and a New SEC Playbook - While summer temperatures continue to sizzle, things cooled considerably at the SEC in the second quarter of 2025. In this Snapshot, we examine Chairman Paul Atkins’...more

BCLP

UK Corporate Briefing - July 2025

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Welcome to the Corporate Briefing, where we review the latest developments in UK corporate law that you need to know about. In this month’s issue we discuss...more

Saul Ewing LLP

Correcting Liquidity, Valuation, or Transfer Problems With OTC-Traded Stocks in Retirement Plans to Minimize Enforcement and...

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Over 8,000 stocks trade on American stock exchanges, but billions of dollars in daily trades in these listed stocks and 12,000 more unlisted (non-exchange-traded) stocks occur outside of an exchange in Over-The-Counter...more

BCLP

Don’t Forget Accounting Rules When Accelerating Vesting of Stock-Based Awards

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Last month, the SEC settled charges against Celsius Holdings, Inc. for allegedly improper accounting when it modified equity compensation awards for six departing employees and retiring directors. The errors caused allegedly...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

Cooley LLP

Enforcement offers a reminder about disclosures of related-person transactions

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Just in time for the commencement of proxy season we have this reminder from SEC Enforcement about disclosures of related-person transactions. Failure to properly report on a related-person transaction has been a subject of...more

BCLP

Perk Redux - Yet Another Company Stumbles Over SEC Executive Compensation Rules

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On December 17, 2024, the SEC announced settled charges against Express, Inc. for failing to disclose perks paid to its then CEO, including personal use of airplanes. Without admitting or denying the SEC’s findings,...more

Skadden, Arps, Slate, Meagher & Flom LLP

2024 Compensation Committee Handbook

Overview of Committee Member Responsibilities - Compensation committee (Committee) members’ duties and responsibilities generally are outlined in the Committee’s organizational charter approved by the board of directors...more

Mayer Brown Free Writings + Perspectives

The SEC Brings Another Enforcement Action On Related Party Transaction Disclosures

On March 7, 2024, the Securities and Exchange Commission (the “SEC”) announced that Skechers U.S.A. Inc. (“Skechers”) agreed to a cease-and-desist order for failing to disclose payments for the benefit of its executives and...more

White & Case LLP

The SEC’s Settlement with Cloopen Demonstrates the Significant Benefits of Prompt Cooperation

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On February 6, 2023, the US Securities and Exchange Commission ("SEC") announced that it settled accounting fraud charges against Cloopen Group Holding Limited ("Cloopen" or the "Company"), a cloud-based communications...more

WilmerHale

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

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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

Proskauer - Regulatory & Compliance

SEC Adopts New SPAC Rules

On January 24, 2024, the SEC adopted new rules that apply to SPAC transactions and the adopted rules largely track the agency’s proposals with some notable exceptions. The new rules will become effective 125 days after...more

Davis Wright Tremaine LLP

Broker Dealer Regulatory Digest - December 2024

The following newsletter provides a roundup summarizing enforcement actions, guidance, rulemakings, and other public statements taken by a federal and/or state financial services regulatory agency, specifically focusing on:...more

Sheppard Mullin Richter & Hampton LLP

CFPB Files Action Against Fintech for Allegedly Violating Previous Order, Deceiving Customers, Withdrawing Funds Without Consent

On November 15, the CFPB issued an order requiring an Illinois-based fintech lender to pay $15 million in fines. The order additionally prohibits the company from operating in certain lines of business and requires revision...more

Thomas Fox - Compliance Evangelist

Albemarle FCPA Enforcement Action: Part 5-Lessons Learned

Over the past several blog posts, I have been exploring the Albemarle FCPA enforcement action.  We have explored in some detail the DOJ Non-Prosecution Agreement (NPA) and the SEC Administrative Order(Order). In this final...more

Holland & Knight LLP

Executive Perks: A Hammer Finds Its Nail in SEC Settlement with Tool Company

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We return once more to the issue of public company executive perquisites or "perks" – a topic we anticipated last year would "be a hot-button enforcement issue for the foreseeable future." We were not wrong. In light of the...more

Pillsbury Winthrop Shaw Pittman LLP

Los Angeles Initiative Seeks to Impose $450,000 Cap on Annual Compensation of Executives in Health Care Facilities

The Los Angeles City Council will soon decide whether to adopt an initiative as an ordinance or refer it to voters for the 2024 ballot. If the initiative officially qualifies for the ballot, the Los Angeles City Council...more

Perkins Coie

DOJ Announces Pilot Program and Updated Expectations on Corporate Compensation Programs

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The U.S. Department of Justice (DOJ) on March 3, 2023, unveiled a new pilot program and announced several important updates to its Evaluation of Corporate Compliance Programs (ECCP) regarding corporate compensation incentives...more

Sheppard Mullin Richter & Hampton LLP

DOJ Revises Guidance on Evaluation of Corporate Compliance Programs Concerning Compensation and Employee Use of Personal Devices...

Following remarks made on March 2 and March 3, 2023 at the American Bar Association’s 38th Annual National Institute on White Collar Crime, the U.S. Department of Justice (“DOJ”) issued revisions to its Evaluation of...more

Akin Gump Strauss Hauer & Feld LLP

New DOJ Focus on Executive Compensation in Resolving Criminal Investigations

Key Points - The DOJ recently announced several policy updates tethering resolution of criminal investigations to a company’s compensation and bonus programs. These updates include executive compensation focused...more

McDermott Will & Emery

[Webinar] 2023 Enforcement Outlook Series: Protecting Your Business Against Non-Compliance and DOJ Penalties - March 23rd, 12:00...

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During speeches earlier this month, Deputy Attorney General Lisa Monaco and Assistant Attorney General for the Criminal Division Kenneth A. Polite, Jr. announced significant changes to the way DOJ evaluates corporate...more

Mayer Brown Free Writings + Perspectives

Disclosing Perks and Payments

The Securities and Exchange Commission recently announced a settlement with Oregon-based freight transportation supply company, The Greenbrier Companies Inc., and founder and former CEO and Chairman, William A. Furman, for...more

McDermott Will & Emery

DOJ Announces Major Changes to Corporate Compliance Program Evaluation Criteria

During speeches on March 2 and 3, 2023, at the American Bar Association (ABA) National Institute on White Collar Crime (the 2023 White Collar Conference), Deputy Attorney General (DAG) Lisa Monaco, Assistant Attorney General...more

Orrick, Herrington & Sutcliffe LLP

U.S. Department of Justice Rolls Out New Policy to Incentivize Companies to Implement Executive Compensation Systems that...

During a March 2, 2023, speech in Miami at the annual American Bar Association National Institute on White Collar Crime, Deputy Attorney General Lisa Monaco announced a new policy designed to incentivize companies to factor...more

Society of Corporate Compliance and Ethics...

CEP Magazine - December 2022. Good things happen when enforcement listens

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

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