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Cooperation Self-Reporting Remedial Actions

White & Case LLP

SEC Enforcement Director Outlines His View of Effective Cooperation

White & Case LLP on

In February 2024, we published an alert discussing the significant benefits of prompt self-reporting and cooperation during a US Securities and Exchange Commission ("SEC") investigation. This past week, during his keynote...more

Katten Muchin Rosenman LLP

FINRA Releases New Guidance on Credit for Extraordinary Cooperation

On July 11, FINRA released Regulatory Notice 19-23 (the Notice),1 which provides welcome details on the ways that firms and individuals can receive credit for extraordinary cooperation in connection with an investigation in...more

WilmerHale

FINRA Issues New Guidance on Cooperation

WilmerHale on

On July 11, 2019, the Financial Industry Regulatory Authority (“FINRA”) restated and supplemented prior guidance regarding the circumstances under which FINRA will award credit for “extraordinary cooperation” in...more

King & Spalding

Above and Beyond: FINRA Clarifies Its Approach to Assessing Extraordinary Cooperation

King & Spalding on

FINRA yesterday issued long-anticipated guidance concerning credit for extraordinary cooperation in the context of enforcement investigations. Like its government counterparts, FINRA hopes to incentivize member firms that go...more

Holland & Knight LLP

Cooperation Credit in False Claims Act Cases

Holland & Knight LLP on

Companies facing liability under the False Claims Act (FCA) often desire early resolution with the Department of Justice (DOJ) through settlement. Hand in hand with the decision to settle comes the decision of whether or not...more

Dorsey & Whitney LLP

DOJ’s New FCPA Pilot Program: The Offer of Enhanced Credit

Dorsey & Whitney LLP on

DOJ’s continuing focus on individuals has spawned a new one year FCPA Pilot Program which offers companies enhanced cooperation credit The new Pilot Program is part of an overall effort to bolster FCPA compliance. Those...more

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