News & Analysis as of

Internal Controls Enforcement Actions

The Volkov Law Group

John Deere Reaches $9.9 Million Settlement with SEC over FCPA Violations

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The U.S. Securities and Exchange Commission (“SEC”) recently instituted proceedings against Deere & Company (“John Deere”), a leading global manufacturer of agricultural and heavy machinery, for multiple violations of the...more

Holland & Knight LLP

DOJ Brings Suit Against University Under Its Civil Cyber-Fraud Initiative

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Late last week, the U.S. Department of Justice (DOJ) filed its complaint-in-intervention in a qui tam lawsuit against the Georgia Institute of Technology (Georgia Tech), alleging that the university failed to meet certain...more

WilmerHale

Making the Connection - What Do Recent SEC Enforcement Actions Mean for Cyber Controls?

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On July 18, 2024, the U.S. District Court for the Southern District of New York dismissed most of the claims brought by the Securities and Exchange Commission (the “Commission”) against SolarWinds Corp. and its Chief...more

Goodwin

Supervisory Experience and Enforcement Actions Continue to Drive Supervisory Priorities and Policy Development

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This article identifies themes we have observed in recent public formal enforcement actions issued to institutions by the US federal bank regulatory agencies (Agencies) — the Board of Governors of the Federal Reserve System...more

A&O Shearman

Judge dismisses most of SEC’s suit against SolarWinds over cybersecurity disclosures

A&O Shearman on

On July 18, 2024, U.S. District Judge Paul Engelmayer of the U.S. District Court for the Southern District of New York issued a comprehensive 107-page opinion that may have significant implications for the Securities and...more

Health Care Compliance Association (HCCA)

So many reporting systems!

By the time you read this, a new U.S. Department of Justice (DOJ) pilot program providing financial rewards to whistleblowers may already be underway. As I write this in late May, DOJ is in the midst of what is called a...more

The Volkov Law Group

Deep Dive into Proposed Boeing Plea Agreement (Part II of III)

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DOJ and Boeing have entered into a proposed plea agreement that will require judicial scrutiny and determinations of the public interest and the victims’ rights under the Crime Victims’ Rights Act, 18 U.S.C. § 3771 [“CVRA”]. ...more

White & Case LLP

Judge Rejects SEC’s Aggressive Approach to Cybersecurity Enforcement

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On July 18, 2024, a New York federal judge dismissed most of the US Securities and Exchange Commission’s ("SEC") claims against SolarWinds Corp. ("SolarWinds" or the "Company") and its Chief Information Security Officer...more

Holland & Knight LLP

Court in SolarWinds Case Blows Down SEC's Cyber Enforcement Authority

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The U.S. District Court for the Southern District of New York on July 18, 2024, dismissed most of the SEC's landmark cyber enforcement litigation against SolarWinds Corp. (SolarWinds or the Company) and the Company's Chief...more

Thomas Fox - Compliance Evangelist

Navigating the New Frontier: SEC’s Enforcement Action on RR Donnelley and its Implications for Compliance

In the ever-evolving compliance landscape, the recent enforcement action by the Securities and Exchange Commission (SEC) against RR Donnelley is a significant case study. This incident underscores the importance of robust...more

The Volkov Law Group

SEC Expands Internal Controls Provision to Cover Cybersecurity Incidents and Reaches $2.1 Million Settlement with R.R. Donnelley &...

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In a significant expansion of internal controls enforcement, the SEC announced a $2.1 million settlement with R.R. Donnelley & Sons Co. (“RRD”) for its handling of a 2021 ransomware attack and resulting disclosure failures. ...more

Holland & Knight LLP

SEC Expands Scope of Internal Accounting Controls in Cybersecurity Breach Settlement

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The SEC continues to expand its cybersecurity enforcement authority to include allegations that a company's failure to monitor its managed security service providers (MSSP) amounts to violations of federal securities laws....more

BakerHostetler

The SEC’s Regulation of Cybersecurity Continues

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The Securities and Exchange Commission entered into a resolution agreement with R.R. Donnelley & Sons (RRD) on June 18, 2024 with RRD agreeing to pay $2.125 million to resolve disclosure and control violations alleged by the...more

Thomas Fox - Compliance Evangelist

The FCPA Survival Guide

I am thrilled to announce my first podcast series based on a book I have written. The book and the podcast series are titled FCPA Survival Guide and Ethico sponsors. The book is available in the Kindle format, and you can...more

Thomas Fox - Compliance Evangelist

Internal Controls and Humans in the Loop: Lessons from Citigroup’s $126 Million Mistake

In the world of compliance and ethics, the Citigroup internal control debacle serves as a glaring reminder of the critical importance of robust, well-designed, functioning and effective internal controls. The U.K. Financial...more

Womble Bond Dickinson

Federal Trade Commission Strikes Against “Crafted in America” Language

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As previously reported by Home Textiles Today, the Federal Trade Commission (FTC) has announced a “record civil penalty” of $3.175 million against a retailer who failed to tell the truth about whether the products it sells...more

Latham & Watkins LLP

SEHK Suspends Trading in Hong Kong Listed Company Pursuant to SFC’s Directions

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The SFC exercises its powers to order the suspension of trading in shares in a listed company to protect investors’ interests. On 15 April 2024, The Stock Exchange of Hong Kong Limited (SEHK) suspended trading in the...more

Latham & Watkins LLP

Key Regulatory Updates for Hong Kong Listed Companies - January/February 2024

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The updates include a report from the Stock Exchange of Hong Kong Limited on review of issuers’ annual reports, a summary of private reprimands, and disciplinary actions....more

Holland & Knight LLP

Aumentan las sanciones por incumplimiento del SAGRILAFT y PTEE en empresas Colombianas

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Dada la relevancia que actualmente está obteniendo la prevención de los riesgos y el cumplimiento normativo en el desarrollo de los negocios, la Delegatura de Asuntos Contables y Económicos de la Superintendencia de...more

Thomas Fox - Compliance Evangelist

Ten Top Lessons from Recent FCPA Settlements-Lesson No. 9, Internal Controls

Over the past 15 months the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) has made clear through three Foreign Corrupt Practices Act (FCPA) enforcement actions and speeches, their priorities in...more

J.S. Held

INDEPTH FEATURE: Anti-Money Laundering 2024

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Could you provide an insight into recent trends shaping financial crime in your country of focus? How great a risk does money laundering in particular now pose to companies? One would likely never imagine compliance as...more

Morrison & Foerster LLP

Top 10 International Anti-Corruption Developments for November 2023

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Designed for busy in-house counsel, compliance professionals, and anti-corruption lawyers, this newsletter summarizes some of the most important international anti-corruption law and enforcement developments from the past...more

Morrison & Foerster LLP

Top 5 SEC Developments (November 2023)

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Each month, we publish a roundup of the most important SEC enforcement developments for busy in-house lawyers and compliance professionals. This month, we examine: • The SEC’s announcement of its Fiscal Year 2023 enforcement...more

Holland & Knight LLP

Called to Account: SEC's Latest Internal Accounting Controls Action Reignites Debate

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Several years ago, the U.S. Securities and Exchange Commission (SEC) issued an order against a public company that raised more than a few eyebrows. In that order, the company settled to violations of Section 13(b)(2)(B) of...more

Foley & Lardner LLP

What Every Multinational Company Should Know About . . . Implementing an International Compliance Program (Part I)

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Record penalties for violations of U.S. regulations governing international conduct and transactions illustrate the risk of costly enforcement actions facing multinational companies. Yet, many multinational companies lack...more

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