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For more than 10 years, federal investigators, led by the Special Inspector General for the TARP (SIGTARP) have, in coordination with the Department of Justice (DOJ), Federal Bureau of Investigations (FBI), Securities Exchange Commission (SEC), Internal Revenue Service (IRS), Financial Crimes Enforcement Network (FinCEN), Small Business Administration (SBA) and other investigative agencies, investigated criminal conduct in connection with the 2008 recession-era TARP program. From those investigations, U.S. Attorneys across the country brought cases and earned convictions for offenses spanning the federal criminal code.
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By Jonathan B. New, Jimmy Fokas, Patrick T. Campbell and Bari R. Nadworny
In recent months, the Dept. of Justice has raised expectations for companies to use data analytics to monitor the effectiveness of their compliance programs and to identify potential misconduct.
A roundtable discussion on the topic of government investigations, corporate compliance efforts, and the potential for fraud or misbehavior in the time of COVID-19.
By Steven Paradise and Matthew Catalano
Gamm v. Sanderson Farms, establishes a high burden for a plaintiff to plead adequately failure to disclose illegal conduct — regardless of how much circumstantial evidence a plaintiff is able to amass or how much news coverage the alleged conduct attracts.
By Jacqueline C. Wolff
Something Old, Something New, Something Borrowed, Something Blue
this second edition contains some new “hypotheticals” — facts of actual cases the DOJ finds important enough to focus on — and, in keeping true to its name, has included additional resources and links for chief compliance officers looking to design and audit their companies’ anticorruption compliance programs.