Topic
Individual Accountability
63 published works
The D&O Diary
Guest Post: The SEC Wants Your Officers, Not Just Your Checkbook
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…
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…
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…
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…
Cartel Capers
The Deterrent Dilemma: Individuals or Corporations? It Should Be Both.
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…
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…
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.…
The D&O Diary
Updated DOJ Corporate Enforcement Policies Emphasize Individual Accountability
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…
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…
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…