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Individual Accountability

63 published works

  1. The D&O Diary

    Guest Post: The SEC Wants Your Officers, Not Just Your Checkbook

    By Kevin LaCroix

    Ashwin Ram Historically, companies have resolved SEC enforcement proceedings by agreeing to pay a fine or penalty, with the payment funds drawn from the corporate treasury. More recently, the agency…

  2. FCPA Professor

    The Gap In SEC Individual FCPA Enforcement Actions Is Approaching 4 Years

    By Mike Koehler

    One reason to take FCPA enforcement agency rhetoric with a grain of salt is because it is warranted. For instance, the FCPA enforcement agencies often talk about the importance of…

  3. FCPA Professor

    The Gap In SEC Individual FCPA Enforcement Actions Is Now Over 3.5 Years

    By Mike Koehler

    One reason to take FCPA enforcement agency rhetoric with a grain of salt is because it is warranted. For instance, the FCPA enforcement agencies often talk about the importance of…

  4. FCPA Professor

    The Gap In SEC Individual FCPA Enforcement Actions Is Over Three Years

    By Mike Koehler

    One reason to take FCPA enforcement agency rhetoric with a grain of salt is because it is warranted. For instance, the FCPA enforcement agencies often talk about the importance of…

  5. Cartel Capers

    The Deterrent Dilemma:  Individuals or Corporations?  It Should Be Both.

    By Robert Connolly

                At the recent American Bar Association’s National Institute on White Collar Crime, Deputy Attorney General Lisa O. Monaco and Assistant Attorney General Kenneth A. Polite gave major talks outlining…

  6. Cleary Enforcement Watch

    Department of Justice Announces Revisions to Criminal Division Policies

    By Jonathan S. Kolodner, Jennifer Kennedy Park, Lisa Vicens, Andres Felipe Saenz, Roberta Mayerle

    On March 3, 2023, Assistant Attorney General (“AAG”) Kenneth A. Polite announced revisions to two Department of Justice (the “DOJ”) Criminal Division policies and the launch of a new pilot…

  7. FCPA Professor

    A Focus On SEC Individuals Actions

    By Mike Koehler

    This previous post highlighted various facts and figures from 2022 SEC FCPA enforcement actions against issuers. This post focuses on SEC FCPA individual actions – both in 2022 and historically.…

  8. The D&O Diary

    Updated DOJ Corporate Enforcement Policies Emphasize Individual Accountability

    By Kevin LaCroix

    In a September 15, 2022 speech, Deputy Attorney General Lisa Monaco announced new Department of Justice guidelines for prosecutors to use when assessing corporate criminality. Although the new guidelines address…

  9. Public Chatter

    DOJ Announces Sweeping Policy Updates for Corporate Criminal Enforcement and Individual Accountability

    By Broc Romanek

    As noted in this Update penned by Jamie Schafer and Gina LaMonica, Deputy Attorney General Lisa Monaco announced several significant policy updates affecting the DOJ's enforcement practices for both corporations and individuals…

  10. FCPA Professor

    The Gap In SEC Individual FCPA Enforcement Actions Is Approaching Two Years

    By Mike Koehler

    One reason to take FCPA enforcement agency rhetoric with a grain of salt is because it is warranted. For instance, the FCPA enforcement agencies often talk about the importance of…