Big violations are easy to define and the bad actors most always know they are engaging in wrongdoing, but what constitutes a small violation worthy of the costs and ramifications of a federal civil prosecution? Where will the SEC draw that blurry line between conduct that is unlawful versus merely unethical? Or, in the eyes of the SEC, is the largely undefined concept of unethical corporate financial behavior always unlawful? If so, then are we seeing the dawn of an ethics-based enforcement program?
This article addresses the importance of defining and identifying unethical corporate conduct, the pitfalls that can result from unethical behavior, and best practices for creating an environment of ethical corporate compliance.
‘Enforcement 40’ for 2020
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