Posted inRegulatory Enforcement

Lowdown on Corporate Charging Decisions

Nobody ever wants to end up sitting across the table from federal prosecutors. But if the worst happens, here’s what compliance officers and corporate counselors need to know about how charging decisions are made when corporate wrongdoing occurs, straight from current and former law enforcement officials. Current and former federal prosecutors speaking at Compliance Week’s […]

Posted inRegulatory Enforcement

Exec Comp Reform Debate Picks Up Steam

The national debate on executive compensation reform picked up steam this week, as the Treasury Department laid out its principles for compensation reform, unveiled its Interim Final Rule on the compensation and corporate governance standards that apply for TARP recipients, and appointed Kenneth Feinberg as Special Master for TARP Executive Compensation (aka the Pay Czar). […]

Posted inRegulatory Enforcement

SEC Heal Thyself: Compliance Program Revamped

The Securities and Exchange Commission just hasn’t had enough bad news recently, so last month the media piled on even more: a probe of insider-trading allegedly going on inside the SEC. Specifically, the agency’s inspector general has found evidence of “suspicious activity, appearances of improprieties, and … possible trading on non-public information, and/or potential insider […]

Posted inRegulatory Enforcement

Keeping Compliance Effective in Difficult Times

By all accounts, the tough economic environment has created an even tougher enforcement environment for Corporate America. Companies shouldn’t expect that to improve any time soon. “There’s a simple but sobering reality right now,” former Deputy Attorney General Paul McNulty, now at the law firm of Baker & McKenzie, told several hundred compliance officers attending […]

Posted inInternal Controls

SEC’s Aguilar on 404, IFRS Proxy Access, More

Smaller companies should prepare to become “more familiar” with the auditor attestation requirement under Section 404(b) of the Sarbanes-Oxley Act, an SEC commissioner told a group of compliance officers gathered in Washington D.C. The SEC’s cost-benefit study on Section 404 is “close to final” and the anecdotal evidence is that “the hard learning that the […]

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