DPAs have been used with great success by DOJ. In such cases, the advantages are clear: the avoidance of criminal convictions, imprisonment for individuals, and potentially devastating collateral consequences for companies. Based upon Tenaris’ example, it is less clear how companies will benefit from entering into DPAs with the SEC, much less that DPAs will be the “game changer” promised by the SEC last year.
‘Enforcement 40’ for 2020
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