In late December 2016, Teva Pharmaceutical Industries Ltd. (“Teva”), the world’s largest generic pharmaceutical manufacturer, entered into a deferred prosecution agreement (“DPA?...
On Wednesday, December 21, 2016, Brazilian construction conglomerate Odebrecht S.A. and its affiliate Braskem S.A. pled guilty in the United States District Court for the Eastern District...
The SEC issued two orders concerning violations of Exchange Act Rule 21F-17 this week. On December 19, the Commission issued an order concerning NeuStar Inc., a technology company based ...
On December 5, 2016 the PCAOB announced that it had settled charges against Brazil-based Deloitte Touche Tohmatsu Auditores Independentes for a record $8 million civil penalty. PCAOB News...
To be guilty of insider trading, a tipper of inside information must receive a “personal benefit” in exchange for his tips. On December 6, 2016, the Supreme Court unanimously held in ...
On May 23, 2016, the United States Court of Appeals for the Second Circuit reversed a $1.3 billion civil penalty imposed against Countrywide Home Loans, Inc., Bank of America, N.A., and r...
On April 5, 2016, the U.S. Department of Justice (“DOJ”) launched a new one-year pilot program encouraging voluntary self-disclosure of misconduct related to the Foreign Corrupt Pract...
A recent Court of Appeals decision sharply limits the authority of judges to reject Deferred Prosecution Agreements (“DPAs”). On April 5, 2016, the U.S. Court of Appeals for the Distr...
In two recent cases, the SEC affirmatively decided not to bring clawback actions under Section 304 of the Sarbanes-Oxley Act (“SOX”) against executives who reimbursed their respective...
2015 proved to be a year of continued focus on anti-corruption enforcement. We have distilled key aspects of the year’s enforcement trends and resolutions to offer you succinct summarie...
