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Think Because You Are a Private Company the SEC Is Not Your Problem? Think Again (and review those separation agreements)

What: Twice this month, the Securities and Exchange Commission (SEC) announced settled actions against entities for violating SEC Rule 21F-17(a) related to language in their separation agreements, including one against a...more

DOJ’s “Carrot” Approach to Corporate Enforcement Policy (But Read the Fine Print)

Last Tuesday, the Department of Justice (DOJ) announced the most recent modifications to its Criminal Division Corporate Enforcement and Voluntary Self-Disclosure Policy (CEP) in an effort to further encourage companies to...more

2021 FCA Recoveries Bounce Back from Decade-Low . . . Maybe

On February 1, the U.S. Department of Justice (DOJ) announced the second-largest annual total recoveries in the history of the False Claims Act (FCA)—$5.6 billion—for FY 2021 (October 2020 – September 2021)...more

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