Cooperation
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First-ever DOJ-wide corporate enforcement policy announced
The new policy supersedes the existing patchwork of voluntary self-disclosure policies, replacing them with a framework applicable across the DOJ.
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SDNY’s new corporate enforcement policy charts path to declination
SDNY said after a company self-reports, it will issue a conditional letter stating intent to decline prosecution, if certain criteria are met.
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Podcast: Sandra Moser and John Pease walk us through DOJ’s Corporate Enforcement Policy
Moser and Pease talk about a corporate enforcement and voluntary self-disclosure policy that has seen a variety of iterations through several administrations.
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DOJ relaxed its approach to corporate criminal enforcement (again)
Citing a need for transparency in the DOJ’s corporate criminal enforcement efforts, Deputy AG Argentieri outlined some tweaks to the agency’s Corporate Enforcement Policy.
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CFTC orders BNY Mellon to pay $5m for swap reporting, supervision lapses
The CFTC said the firm failed to properly supervise its swap dealer business with respect to swap data reporting.
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SEC’s Grewal on cyber resilience and his division’s approach
Gurbir Grewal set out the Division of Enforcement’s five guiding principles.
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SEC charges Stanley Black & Decker over executive perks disclosure
SEC settles charges against Stanley Black & Decker for failing to disclose perks it provided certain executives, but imposes no money penalty.
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Company self-reporting on rise, says AAG Polite, and work of CCOs is integral
AAG Polite said the criminal division is also looking into how it selects compliance monitors and when it charges individual executives.