Recent Posts

An Example of Cooperation Credit From the SEC
Posted on 14 Jul 2015 by Thomas O. Gorman

DOJ and SEC officials repeatedly encourage cooperation. There are benefits for both sides. Cooperation can facilitate the Government’s investigation, providing a road to the scheme. Testimony can aid in obtaining a favorable result. For the cooperator... Read More

A “New Era” of FCPA Enforcement
Posted on 17 Nov 2010 by Thomas O. Gorman

"We are in a new era of FCPA enforcement" Assistant AG Lanny Breuer declared in remarks at a conference on Tuesday . The Department of Justice is stepping up FCPA enforcement, which is good for business, despite the contention of some critics... Read More

The Benefits of Cooperation
Posted on 25 Jun 2014 by Thomas O. Gorman

Enforcement officials frequently emphasize the benefits of cooperation. The cases involving former Credit Suisse Managing Director David Higgs illustrate the point. U. S. v. Higgs, 1:12-cr-00088 (S.D.N.Y. Plea February 1, 2012); SEC v. Kareem Serageldin... Read More

Important Guidance on SEC Cooperation Standards
Posted on 20 Mar 2012 by Thomas O. Gorman

When the SEC announced an initiative to encourage cooperation with its enforcement investigations by individuals a key focus was speed and efficiency for the Division. The idea was that a cooperating witness could speed investigators through the mountain... Read More