Remediation
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OPINION: Why remediation fails after notice
Structural persistence, compliance theater, and the limits of institutional correction.
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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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FCA Market Watch: Remediation, back reporting and breach notifications
FCA highlights issues in MiFID reporting requirements and advises firms to update and improve their processes.
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DOJ clarifies its CEP with a focus on self-reporting and compliance monitors
A company can expect a declination when it voluntarily discloses corporate misconduct, cooperates, and remediates violations.
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Podcast: Andrew McBride on the FCPA, compliance, and cooperating with government
Julie DiMauro spoke to the founder and CEO of Integrity Bridge, and former Chief Risk & Compliance Officer of Albemarle Corporation.
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Goldsmith Romero outlines her recommendations for cooperation credit at the CFTC
Commissioner Goldsmith Romero said her agency should make the benefits of cooperation more clear in public documents and specific cases.
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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 Commissioner Mersinger on cooperation credit and avoiding chasing trends
Mersinger’s remarks revolved around CFTC enforcement and ideas for improvement, especially in the extension of cooperation credit.