In a recent speech to the New York City Bar Association’s Compliance Institute, Gurbir Grewal, Director of the Securities and Exchange Commission’s Division of Enforcement, emphasized the importance of creating a culture of proactive compliance within any corporate organization and shared some important insights into the Division’s thinking about enforcement actions and penalties. Specifically, he offered three “E’s”—Education, Engagement, and Execution—as pillars of any effective corporate compliance program. And while these pillars may seem obvious to any practitioner, behind each is a preview of the SEC’s enforcement priorities going forward and a blueprint for public companies to design audits and internal investigations to identify any latent potential issues.
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