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OFAC to Companies: Don’t Forget Your U.S. Persons

On September 27, 2021, the Office of Foreign Assets Control (“OFAC”) of the U.S. Department of Treasury announced a $1,423,766 settlement with Houston-based supplier, Cameron International Corporation (“Cameron”) to resolve...more

U.S. Securities and Exchange Commission Issues a $27 Million Enforcement Reminder

The Securities and Exchange Commission has issued a reminder that when the business world returns to standard operations, enforcement actions will have a stinging bite.  On April 16th the Commission announced that it will...more

DOJ Further Incentivizes Voluntary Disclosure with Small Changes to FCPA Corporate Enforcement Policy

The Department of Justice tweaked its FCPA Corporate Enforcement Policy to further incentivize corporations to make voluntary disclosures. These small changes essentially acknowledge that companies in a very early stage of an...more

Recent SEC Whistleblower Awards Highlight Importance of Internal Reporting

The SEC’s most recent whistleblower awards highlight the importance of internal reporting to a company’s compliance program and especially how a company investigates and responds to such reports.   On May 24, 2019, the SEC...more

CFTC Joins FCPA Enforcement Bandwagon

On March 6, 2019, the Commodity Futures Trading Commission (CFTC) issued an Enforcement Advisory that applies to companies and individuals not registered with the CFTC that voluntarily disclose violations of the Commodities...more

Anti-Corruption Enforcement Webinar: 2018 in Review

Anti-Corruption enforcement remained a top priority in France, the UK, and the US in 2018. Join our firm's Global Anti-Corruption Team as they explain and analyze these three countries' anti-corruption enforcement efforts and...more

SEC Announces More than $20 Million in Whistleblower Awards

In the course of one week, the United States Securities and Exchange Commission announced awards to three whistleblowers totaling more than $20 million under the Dodd-Frank Whistleblower Program. On November 30, the SEC...more

SEC Announces $20 Million Whistleblower Award

On November 14, 2016, the United States Securities and Exchange Commission announced an award of at least $20 million to a whistleblower for providing information that initiated a successful investigation and enforcement...more

SEC Targets Whistleblower Retaliation

The Securities and Exchange Commission (SEC) recently announced a settlement with a Nevada corporation of its first stand-alone whistleblower anti-retaliation case. On September 29, the SEC announced a $500,000 sanction...more

You May Not Stack the Deck: SEC Announces Penalties Against Companies Requiring Employees to Waive Whistleblower Protections to...

The Securities and Exchange Commission (“SEC”) recently announced that two companies agreed to pay penalties of more than $500,000, combined, for illegally requiring employees to waive their rights to monetary awards from the...more

Substantial Awards Available for the Taking: SEC Announces $17 Million Whistleblower Award

On June 9, 2016, the United States Securities and Exchange Commission announced its second largest award under the agency’s Dodd-Frank Whistleblower Program. This is the largest such award issued since the SEC issued a $30...more

Whistling Fast and Furious: The SEC Issues Two Multimillion Dollar Awards to Whistleblowers

In the past week, the SEC has issued two multimillion dollar awards to whistleblowers. The announcement of two significant awards in quick succession suggests that the “significant uptick” in in the number of tips noted by...more

EB-5 Program Update – SEC Orders $3.2 Million in Disgorgement Against Unregistered Broker-Dealers

So you want to use the government’s EB-5 Immigrant Investor Program (“EB-5 Program”) to raise cash? Be aware that the SEC will be looking over your shoulder to determine whether you are acting as an unregistered broker-dealer...more

SEC Touts Continued Uptick in Whistleblower Tips

On Tuesday, March 8, 2016, in conjunction with announcing a recent $2 million whistleblower award, Sean McKessey, Chief of the Office of the Whistleblower, stated that the SEC continues to see “a significant uptick” in the...more

SEC $700K External Whistleblower Award Highlights Need for Watchful Compliance Programs

Last week, the SEC announced an award of $700,000 to a company outsider who conducted a “detailed analysis” resulting in a successful SEC enforcement action. In a press release, Andrew Ceresney, director of the SEC’s Division...more

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