George Kostolampros advises and represents clients in investigations and litigation brought by the U.S. Securities and Exchange Commission (SEC), the Commodity Futures Trading Commission (CFTC), the Department of Justice (DOJ), U.S. Attorney’s Offices, Financial Industry Regulation Authority (FINRA), state AGs, and other government agencies and self-regulatory bodies at federal and state levels. George handles matters relating to securities enforcement defense, internal investigations, and anti-corruption issues.  George represented clients in an SEC litigation that resulted in a Court of Appeals vacating the underlying SEC administrative proceeding in the matter and ultimately the SEC agreeing to dismiss claims against the individual respondents.

Deciding whether to voluntarily disclose information to the government is difficult. Any guidance from the government as to what it expects from organizations and how it will reward self-disclosures should thus be welcome.

In a recent appearance at a conference on the Foreign Corrupt Practices Act, Deputy Attorney General Rod Rosenstein announced several changes to DOJ’s corporate enforcement policy. Notably, his statements rolled back some of the requirements set forth in the eponymous “Yates Memo” from 2015. In this blog post, we’ll highlight two key policy differences between the Yates Memo and the updated DOJ policy.

First, DOJ is changing how companies may earn credit for cooperating with civil and criminal investigations. The Yates Memo advanced more of an “all or nothing” approach, where companies had to disclose the wrongdoing of all individuals involved in a corruption scheme. Failure to disclose information related to all individuals precluded companies from earning any cooperation credit.Continue Reading DOJ Signals Changes to Its Corporate Enforcement Policy

In this issue we discuss that under the cloud of speculation hanging over the CFPB they continue to launch supervisory examinations and enforcement investigations, and also held a public event on June 22 discussing the Public Student Loan Forgiveness Program.

Also in this issue is commentary around a top state regulator issued a reminder to