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Financial Services Industry › Disgorgement › Foreign Corrupt Practices Act (FCPA)

A&O Shearman

First DOJ Declination For FCPA Violations Since Renewed Enforcement Guidelines

A&O Shearman on

On August 7, 2025, the United States Department of Justice, Criminal Division, Fraud Section (“DOJ”) issued a declination letter to a U.S.-based insurance company (the “Company”) to resolve alleged violations of the Foreign...more

Akin Gump Strauss Hauer & Feld LLP

The FCA And SEC Annual Reports – A Statistical Comparison

Akin Gump Strauss Hauer & Feld LLP on

Key Points - The SEC and the FCA each publish annual reports on their enforcement actions. Whilst enforcement data only shows a snapshot of the regulators’ activities, there is much to be learned from these reports,...more

Pillsbury Winthrop Shaw Pittman LLP

SEC’s Negotiating Power Curbed - U.S. Supreme Court holds disgorgement subject to a five-year statute of limitations

Pillsbury Winthrop Shaw Pittman LLP on

Earlier this week, the U.S. Supreme Court resolved a circuit split among the Tenth and Eleventh Circuit Courts of Appeals by holding that because disgorgement in a Securities and Exchange Commission (SEC) enforcement action...more

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