The DOJ released the first version of its Evaluation of Corporate Compliance Programs in 2017. That document (with its 2019 and 2020 updates) completed the chief compliance officer’s amazing transformation from part-time generalist to today’s highly specialized “super executive.”… Continue Reading
After this week’s $22 million award to a whistleblower, SEC leaders called the whistleblower program a game changer that has transformed the SEC’s ability to protect investors.
More than $107 million has been awarded to 33 whistleblowers.… Continue Reading
Each year, Ethisphere recognizes 100 individuals who have made a material impact in the world of business ethics and compliance.… Continue Reading
According to its website, VW adopts “a preventive compliance approach and foster[s] a corporate culture that stops potential breaches before they occur.” Well, apparently it does not.
In the U.S.… Continue Reading
In October 2013, SEC Chairwoman Mary Jo White announced a broken windows enforcement policy to “pursue even the smallest infractions” of U.S. securities laws, including the FCPA, as a means of deterrence. … Continue Reading
The SEC proposed Thursday to change the way it conducts administrative proceedings by widening discovery for both parties and requiring pleadings to be handled and served more efficiently.
The agency is using internal procedures more these days instead of going to court to resolve securities law violations, including FCPA offenses.… Continue Reading
Over the past couple of years, the SEC and its chair, Mary Jo White, have given compliance officers plenty of face. Compliance officers are gatekeepers. They guard the integrity of the markets.… Continue Reading
Here’s some of what SEC chair Mary Jo White had to say last week in a speech at Northwestern University School of Law in Chicago, Illinois.… Continue Reading
As first reported last week by Sam Rubenfeld of the Wall Street Journal, the SEC dropped internal controls charges in a civil FCPA action against a current and a former executive at Noble Corporation in order to “streamline the presentation” of the case.… Continue Reading
Mary Jo White, Chair of the Securities and Exchange Commission, outlined her agency’s regulatory and enforcement priorities for 2014 during a talk Monday at the Annual Securities Regulation Institute.
She said more admissions will be sought.… Continue Reading
No one can say they haven’t been warned by the SEC (and the authors of the latest Hughes Hubbard FCPA/Anti-Bribery Alert) not to interfere with compliance officers.
Here’s an excerpt from the Alert about the new effort to protect compliance officers:
Recent statements and actions by the SEC demonstrate that the enforcement agency has adopted a broad strategy of seeking to protect and strengthen the position of compliance officers.… Continue Reading