penalties Archives - Corruption, Crime & Compliance

4 Sep, 2024

SEC Outlines “Effective Cooperation” Standard

The Securities and Exchange Commission is catching up to DOJ. Not in enforcement but in transparency. After years of criticism, the Justice Department has set the gold standard for transparency and providing guidance on enforcement and compliance. The SEC needs to elevate transparency and offer new guidance to the public and industry. It is even more important for the SEC to provide guidance given the...

General

23 Sep, 2015

Checking In on Sanctions Enforcement

The Department of Treasury’s Office of Foreign Asset Control continues to ramp up sanctions enforcement. Even with the likely relaxation of the Iran and Cuba sanctions, OFAC has been continuing its aggressive enforcement program. Thus far, OFAC has collected approximately $270 million in civil penalties, and participated in several major criminal investigations, including Commerzbank and Schlumberger. Commerzbank agreed to pay a total of $1.45 billion...