Tag: cooperation

SEC Enforcement Division FAQs on its SCSD for Advisers

The SEC’s Division of Enforcement issued Frequently Asked Questions and Answers or FAQs for its Share Class Selection Disclosure Initiative or SCSD, initially announced in February 2018. The FAQs clarify and in part reiterate the terms of the initial SCSD

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DOJ Announces New FCPA Cooperation Policy

The Department of Justice announced a revised FCPA Corporate Enforcement Policy. The new policy, designed to enable the DOJ to efficiently identify and punish criminal conduct while encouraging voluntary disclosures of wrong doing, offers the prospect of a declination, or

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