When fraud is identified, or suspected, in an organization, companies and their boards are not always aware of what steps to take. Should they conduct a thorough internal investigation, or should they alert the Division of Enforcement at the Securities and Exchange Commission (SEC) about a potential securities law violation? Are there tangible benefits to self-reporting to the SEC?
The SEC's Division of Enforcement's formal cooperation program includes various measures designed to encourage individuals and companies to provide assistance to SEC investigators. Depending on the level of cooperation, benefits may accrue to those who are proactive.
In this course, panelists have an impactful discussion and explore what questions boards and company management should be asking of their counsel, their chief compliance officers, chief audit executives, and external auditors. At what point should the SEC be informed of potential misconduct? What are the risks if a company does not self-report? Kara Brockmeyer, SEC Foreign Corrupt Practices Act Chief, will share information on the SEC Cooperation Program, including recent enforcement actions involving cooperation agreements, and how the Commission defines "cooperation."