Securities Litigation Review
07 January 2011SEC Client Alert
The Enforcement Division announced an initiative in early 2010 - paralleling Department of Justice (DOJ) policies - offering the carrot of non-prosecution agreements to encourage greater cooperation by companies and individuals. By the end of 2010, however, only one company (Carter's Inc.) had entered into a non-prosecution agreement. And the SEC continued to resort to traditional methods of encouraging cooperation, either by not charging companies with having engaged in fraud and/or not imposing financial penalties (e.g., InfoGroup, Navistar International, International Commercial Television and General Re).
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