Self-reporting

Tony McClements discusses Jonathan Fisher KC’s independent review, “Fraud in the Digital Age” and argues whistleblowers should be compensated.

By voluntarily self-disclosing the violations and cooperating with the DOJ, the testing laboratory avoided open-ended exposure, a corporate integrity agreement, and exclusion from federal programs.

The company avoided criminal prosecution but must still pay a hefty fine.

The advisory gives market participants even more opportunity for full enforcement declinations.

Speakers discussed the enhancements FINRA is making to both divisions and how firms can navigate their way through these processes with better practices.

The aim is to enable users to compare the complaints reported by individual financial firms for the first time, including their handling of complaints associated with specific products.

SDNY said after a company self-reports, it will issue a conditional letter stating intent to decline prosecution, if certain criteria are met.

Speakers emphasized technology‑neutral and principles‑based regulation, teased on new policies to come, or raised red flags.