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Cybersecurity and an'increase in data breaches'isn't merely a U.S. problem. On Dec. 21, the Investment Industry Regulatory Organization of Canada (IIROC), a self-regulatory organization that helps oversee the country's trading industry, released two guides to help investment dealers protect themselves and their clients against cyber attack.
The first guide, titled 'Cybersecurity Best Practices Guide,' is intended as a living document that can be updated to give dealers the latest practices concerning governance and risk management, network security, and more. The 53-page guide also features a cybersecurity incident checklist and a sample vendor assessment.
The DOJ's Criminal Division issued three declinations since the issuance of the revised CEP a year ago. Review of these cases gives insight into DOJ's implementation of the new policy in practice.
This article discusses the practical and policy reasons for the use of DPAs and NPAs in white-collar criminal investigations, and considers the NDAA's new reporting provision and its relationship with other efforts to enhance transparency in DOJ decision-making.
The parameters set forth in the DOJ's memorandum have implications not only for the government's evaluation of compliance programs in the context of criminal charging decisions, but also for how defense counsel structure their conference-room advocacy seeking declinations or lesser sanctions in both criminal and civil investigations.
This article explores legal developments over the past year that may impact compliance officer personal liability.
There is no efficient market for the sale of bankruptcy assets. Inefficient markets yield a transactional drag, potentially dampening the ability of debtors and trustees to maximize value for creditors. This article identifies ways in which investors may more easily discover bankruptcy asset sales.