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Kramer Levin Litigation partners Gary P. Naftalis and Alan R. Friedman authored an article entitled "Encouraging Individual Cooperation in SEC Enforcement Investigations," which appeared in the Summer 2002 edition of the Securities Regulation Law Journal.
The article reviews the SEC's Section 21(a) Report on corporate cooperation. The authors then discuss various tools already at the SEC's disposal that it can flexibly apply to assure that the public interests of deterring misconduct and preventing wrongdoers from profiting from their misdeeds can be met, while at the same time affording substantial credit to individual cooperators, whose assistance is ultimately vital to the Commission's enforcement mission.
Download Encouraging Individual Cooperation in SEC Investigations in PDF format