Both the U.S. Securities and Exchange Commission ("SEC") and the Financial Industry Regulatory Authority ("FINRA") stress the importance of remediation.

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Additionally, the U.S. Department of Justice (“DOJ”) and SEC’s Resource Guide to the U.S. Foreign Corrupt Practices Act (“Resource Guide”) places a “high premium” on remediation in resolution of cases and is a key factor in deciding whether to impose an independent corporate monitor. Similarly, FINRA Regulatory Notice 08-70 (FINRA Reg. 08-70) instructs that timely and effective remediation is one of four factors that FINRA considers in awarding credit for “extraordinary cooperation.”

StoneTurn’s Jonny Frank outlines the key criteria corporations must meet to attempt satisfy the requirements of “remediation” for regulatory bodies.

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Jonny Frank StoneTurn

Jonny Frank

Jonny Frank brings over 40 years of public and private sector and law and business school teaching experience in forensic investigations, compliance, and risk management. He helps organizations and counsel […]

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