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Penalties Enforcement Guidance

Troutman Pepper Locke

DOJ’s Revised Self-Disclosure Policy May Offer Companies More Certainty

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Last month, the DOJ Criminal Division (Division) revised its Corporate Enforcement and Voluntary Self-Disclosure Policy (CEP), introducing several potentially significant changes intended to further incentivize companies to...more

DLA Piper

DOJ’s Revised Policy on Crediting Fines: Emphasis on Victims

DLA Piper on

Without fanfare, the Department of Justice (DOJ or the Department) has published a memorandum revising its policy on when – and how – it will give credit to companies for fines and other payments made to other agencies,...more

Holland & Knight LLP

Colleges and Universities Must Report Certain Foreign Gifts and Contracts

Holland & Knight LLP on

In light of recent enforcement activity, institutions of higher education should review their reporting and disclosure obligations related to foreign entities and individuals under Section 117 of the Higher Education Act (20...more

WilmerHale

Breaking With Precedent - New Guidance on Future CFTC Enforcement Resolutions

WilmerHale on

The Commodity Futures Trading Commission (CFTC) Division of Enforcement recently released a new advisory to its staff related to penalties, corporate compliance monitors and consultants, and admissions in CFTC enforcement...more

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

OSHA Announces Significant Expansion of ‘Instance-by-Instance’ Citation Policy

Late on January 26, 2023, the Occupational Safety and Health Administration (OSHA) issued a press release concerning a significant change in long-standing policy related to instance-by-instance issuance of citations that will...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

K2 Integrity

OFAC Releases Updated Ransomware Advisory and Announces First Designation of Cryptocurrency Exchange

K2 Integrity on

On 21 September 2021, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued an updated advisory that highlights the sanctions risks associated with making ransomware payments. OFAC reiterated...more

Foley & Lardner LLP

Five Key Takeaways From the D.C. Circuit’s PHH Decision

Foley & Lardner LLP on

The legal challenge by PHH Corp. (PHH) to a June 4, 2015, decision by the director of the Consumer Financial Protection Bureau (Bureau) in connection with the Bureau’s enforcement proceeding against PHH has captivated the...more

Bracewell LLP

EPA Updates Its Audit Policy with "eDisclosure"

Bracewell LLP on

On June 10, 2015, the U.S. Environmental Protection Agency hosted a webinar describing a plan to modernize the implementation of its April 11, 2000 Audit Policy. The plan – called eDisclosure – attempts to provide a...more

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