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The U.S. Attorney’s Office for the Southern District of New York (SDNY) announced the creation of a Whistleblower Pilot Program applying to individuals who provide information regarding...
SAP agreed to pay $220 million to resolve a long-standing foreign bribery investigation with the Department of Justice and the Securities and Exchange Commission involving improper paymen...
The recently enacted Foreign Extortion Prevention Act, meant to serve as the mirror image of the Foreign Corrupt Practices Act, criminalizes the solicitation and receipt of bribes by fore...
2023 was an active year in public company enforcement by the U.S. Securities and Exchange Commission, with several first-of-their-kind actions. The SEC looked past traditional financial p...
To help navigate what has been an active year of new SEC disclosure mandates, we have prepared an overview of key considerations for preparing your 2023 annual report on Form 10-K.
In a recent speech, Acting Assistant Attorney General Nicole M. Argentieri laid out how the DOJ is increasing its use of data analytics to proactively identify FCPA cases, deepening its c...
After receiving board approval to buy back stock under a 10b5-1 plan, a company interpreted Rule 10b5-1 in a manner with which the SEC disagreed. The SEC did not allege that the company t...
FinCEN released a proposed rule that would identify international convertible virtual currency mixing as a class of transactions of “primary money laundering concern” – a designatio...
On October 17, 2023, CFTC Director of Enforcement Ian McGinley signaled a more aggressive approach by the agency in new enforcement guidance addressing penalties, admissions, the impositi...
The final rules require current reporting of cybersecurity incidents and annual risk management disclosure for public companies that are likely to compound compliance costs and enforcemen...
