On May 26, 2016, the US Court of Appeals for the Eleventh Circuit issued a decision in SEC v. Graham, curtailing the SEC’s ability to seek disgorgement of allegedly ill-gotten profits beyond five years from the time the claim first accrued.

The DOJ issued a Pilot Program1 that provides its latest answer to a critical question in FCPA practice: What benefits does a company receive for self-reporting potential FCPA violations?

On April 22, 2015, the SEC announced that it had awarded an unidentified company’s unidentified compliance officer with a whistleblower award of between $1.4M-$1.6M for providing the SEC with information that the agency used to bring an enforcement action. (SEC Press Rel. No. 2015-73, April 22, 2015).  This is the second…