Compliance

doj timeliness collage

What the Enforcement Record Says About ‘Timely’ Disclosure

Of the nine enforcement cases CCI examined where companies received credit for timely disclosure, only two included a measurable time window. In several others, the timeliness clock had effectively run out before the company acted — a whistleblower, a press report or a parallel investigation had already answered the question. CCI editorial director Jennifer Gaskin examines what the enforcement record...

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