In the Security and Exchange Commission’s now-famous “Statement on the Relationship of Cooperation to Agency Enforcement Decisions,” the Commission outlined criteria it would consider when determining how much to credit firms for “self-policing, self-reporting, remediation and cooperation.”
According to the statement, cooperative behavior actions by companies could result in reduced charges, lighter sanctions, mitigating language in documents used to announce and resolve enforcement actions, or even “the extraordinary step of taking no enforcement action” (see box at right).
