On Monday, September 23, DOJ’s Criminal Division announced updates to its guidance for evaluating corporate compliance programs (“ECCP”). Principal Deputy Assistant Attorney General Nicole Argentieri also delivered remarks...more
9/27/2024
/ Anti-Retaliation Provisions ,
Artificial Intelligence ,
Compliance ,
Corporate Governance ,
Corporate Misconduct ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Emerging Technologies ,
Incentives ,
Penalties ,
Risk Assessment ,
Risk Management ,
Self-Disclosure Requirements ,
Voluntary Disclosure ,
Whistleblower Protection Policies ,
Whistleblowers
On September 15, 2022, Deputy Attorney General Lisa Monaco announced significant changes to the U.S. Department of Justice’s (DOJ) approach to corporate criminal enforcement, including revised policies and an accompanying...more
On October 28, 2021, Deputy Attorney General Lisa Monaco announced three changes to the Department of Justice’s (DOJ) approach to corporate criminal enforcement. Monaco announced the changes during the Keynote Address at the...more
Three years ago, the Supreme Court ruled in Kokesh v. SEC that disgorgement in the context of an SEC enforcement action functions as a “penalty” for purposes of 28 U.S.C. § 2462 and is therefore subject to a five-year statute...more
6/25/2020
/ 15 U.S.C. § 78u(d)(5) ,
Administrative Authority ,
Business Expenses ,
Calculation of Damages ,
Corporate Misconduct ,
Disgorgement ,
Enforcement Actions ,
Equitable Relief ,
Kokesh v SEC ,
Lack of Authority ,
Liu v Securities and Exchange Commission ,
Net Profits ,
Remedies ,
SCOTUS ,
Securities and Exchange Commission (SEC)