Roberto Finzi

Sep 26, 2024 | lexology.com | L. Atkinson |Jessica Carey |John Carlin |Roberto Finzi |Harris Fischman |Katherine B. Forrest | +1 more

On September 23, 2024, the Criminal Division of the U.S. Department of Justice (“DOJ” or the “Department”) issued an update to its guidance titled Evaluation of Corporate Compliance Programs (the “ECCP”).[1]  The ECCP has been revised periodically since its introduction in 2017, but this 2024 update notably shows the Department’s increasing emphasis on artificial intelligence (“AI”), data analysis, and whistleblower policies.

Aug 7, 2024 | lexology.com | L. Atkinson |H. Christopher Boehning |Walter Brown |Jessica Carey |John Carlin |Roberto Finzi | +13 more

On August 1, 2024, the U.S. Department of Justice’s Criminal Division (“DOJ” or “Department”) launched a new Corporate Whistleblower Awards Pilot Program (the “Whistleblower Pilot Program” or the “Pilot Program”).[1]Under the Pilot Program, eligible whistleblowers who provide the Criminal Division with original and truthful information about certain types of corporate misconduct are eligible to receive a portion of a criminal or civil forfeiture exceeding $1 million.

Mar 18, 2024 | lexology.com | L. Atkinson |H. Christopher Boehning |Walter Brown |Jessica Carey |John Carlin |Roberto Finzi | +5 more

On March 7, 2024, Deputy Attorney General Lisa Monaco (“DAG Monaco”) announced that the U.S. Department of Justice (DOJ) will launch a new whistleblower program this year (the “DOJ Program” or the “Whistleblower Program”) that is intended to “create new incentives for individuals to report misconduct” to DOJ and “drive companies to invest further in their own internal compliance and reporting systems.”[1] While a number of federal agencies currently have whistleblower programs, DAG Monaco...

Feb 15, 2024 | lexology.com | Walter Brown |Susanna M. Buergel |Jessica Carey |John Carlin |Andrew J. Ehrlich |Roberto Finzi | +8 more

During the third year of Chair Gary Gensler’s and Director of Enforcement Gurbir Grewal’s leadership, several key enforcement priorities for the SEC impacted and will likely continue to impact businesses across a range of sectors for years to come. In this year in review, we highlight important takeaways for business leaders and in-house counsel from the Division’s activities in 2023, and what these activities suggest for the Division’s priorities for the year ahead.

Nov 8, 2023 | lexology.com | Jessica Carey |John Carlin |Yahonnes Cleary |Roberto Finzi

On November 1, 2023, New York Superintendent of Financial Services Adrienne A. Harris announced that the New York State Department of Financial Services (“NYDFS”) had finalized updates to the cybersecurity regulations codified in 23 NYCRR 500 (“Part 500”).[1] The now final regulations reflect NYDFS’s effort to ensure that NYDFS-regulated entities implement robust cybersecurity policies and procedures.