The SEC often encourages self-reporting, cooperation, and remediation in speeches and policy statements. In a settled enforcement action announced today, the Commission made clear just how valuable those efforts can be, allowing a company to settle accounting controls and disclosure violations with no financial penalty whatsoever. According to the SEC’s announcement, from 2012 to early … Continue Reading
Government fraud settlements are getting more personal. Which means the Yates memorandum is having its intended effect. Issued in 2015, the memo requires that government attorneys focus more on individual liability when resolving fraud investigations. For example, that year only 6 settlements imposed personal liability on physicians settling complaints filed under the False Claims Act. According to … Continue Reading
Last week, we published the details of the expected Deferred Prosecution Agreement (DPA) that was yet to be approved by the UK’s High Court on 17 January 2017. The Serious Fraud Office (“SFO”) has since now confirmed, that the DPA was approved by Sir Brian Leveson, President of the Queen’s Bench Division, and the DPA, … Continue Reading
