September 23, 2024, Principal Deputy Assistant Attorney General Nicole M. Argentieri announced revisions to the Department of Justice (“DOJ”), Criminal Division’s compliance guidance, known as the Evaluation of Corporate Compliance Programs (“ECCP”), which is used by DOJ prosecutors to assess the effectiveness of a company’s compliance program in the context of a corporate investigation.[1]
DOJ Announces Changes to Guidance on Corporate Compliance Programs, Updates on Whistleblower Program
In an address this week to the Society of Corporate Compliance and Ethics, Principal Deputy Assistant Attorney General Nicole M. Argentieri of the Department of Justice’s (“DOJ”) Criminal Division, highlighted several updates relevant to corporate compliance programs, including the DOJ’s new whistleblower programs and incentives.
SEC Compliance Outreach for Investment Adviser and Investment Company Senior Officers
The Securities and Exchange Commission recently announced that it will host a compliance outreach program on November 7, 2024 (see the program’s agenda) on Advisers Act and Investment Company Act related topics. The agenda covers a broad array of issues from exam priorities and enforcement activities to areas that have been the topic of
An Evening with New York’s Commercial Division Justices 2024: Takeaways & Insights
As recently highlighted by this blog, on September 12, 2024, the Justices of the Commercial Division gathered in the offices of Kelley & Drye to discuss new updates and happenings in the world of the Commercial Division (“ComDiv”). The night was filled with lively discussion – leaving those fortunate enough to attend with valuable insights
Tech Exec Charged with AI-Related Misrepresentations and Fraudulent Revenue Recognition
In recent months, the SEC Chair and other government officials have made it clear that they are closely watching for companies that try to catch the AI wave by making exaggerated or false claims about the AI capabilities of their products or services. In the latest example of the crack down on these kinds of
Gibson Dunn Offers Securities Litigation 2024 Mid-Year Update
This update provides an overview of the major developments in federal and state securities litigation since our Securities Litigation 2023 Year-End Update. A recent NERA Economic Consulting (NERA) study provides an overview of recent developments in filings. This section highlights several notable trends.
Filing Trends
Figure 1 below reflects the federal filing rates from
Quick Question Tuesday, Part 9. What is China’s Game Plan for International Business Relations?
What is China’s Game Plan for International Business Relations?
As lawyers, we spend a lot of time fielding good, bad, weird, interesting, deep, superficial, and all types of other questions from people. We’re generally expected to be oracle-level wizards, a lot like people are treating AI now. In this series, we’ll share some of these
Love is Blind UK and why DIY China Law is SO Dangerous
No More DIY Law, Please
Have you ever made a major business or life decision based on advice from a friend, a blog, or a DIY guide, only to find out later that it was flawed?
Last week provided me with three compelling examples of why lawyers are indispensable in making any legal decisions. In this
Generative Artificial Intelligence 101: Evaluating the Consistency and Reliability of Generative AI for Content Creation
Generative AI still cannot consistently or reliably create content without substantial inaccuracies, racial and gendered biases, or outright fabrications.
In our previous Generative Artificial Intelligence 101 blog post, we defined Generative AI and its many benefits. This time we will discuss why we cannot rely on Generative AI completely, just yet.
While Generative AI
Will Large Language Models Propel Financial Statement Analysis Into a New Era?
Since the introduction of ChatGPT, large language models (LLMs) have completed a variety of tasks with impressive results, from summarizing complex documents to conducting sentiment analysis to extracting relevant information. But are LLMs up to even greater challenges like, say, making informed financial decisions?
In a new paper, we explore whether LLMs can handle financial