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You may have heard of the Yates Memorandum, which sets forth current Justice Department policy on corporate cooperation with criminal investigations. But the Securities and Exchange Commission has just announced another significant policy change, which hasn’t garnered the same attention: self-disclose or forfeit access to key favorable case dispositions.
Continue Reading When Voluntary Self-Disclosure Isn’t so Voluntary: SEC Says Self-Disclose or Forfeit Non-Prosecution and Deferred Prosecution