The Capital Commitment

Proskauer on Private Equity Litigation

Tag Archives: Compliance

To Disclose or Not to Disclose: Navigating the Complex Relationship Between Voluntary Self-Disclosure of Sanctions Violations and Enforcement Response

In the ever-evolving and complex world of economic sanctions, voluntary self-disclosure is frequently the best long-term strategy for any company that discovers a violation of a sanctions regime. The more difficult task is to assess the costs and benefits of self-disclosure in cases where the conduct falls into a gray area. We explain the complex … Continue Reading

Five Things to Think About Before a Surprise SEC Exam

If a team from the SEC arrives at your office and says, “We are conducting an on-site examination and would like to talk to the CCO right now,” are you prepared? A handful of registered investment advisers have faced surprise SEC exams in recent months. These exams come in two flavors: either a “for cause” … Continue Reading
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