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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