Policy Patty Toolkit 

Making the world a little more compliant one toolkit at a time.


DOJ Issues New Guidance on Compliance Monitors

Posted on October 16, 2018 at 7:20 PM
Brian Benczkowski, Assistant Attorney General for the Criminal Division of the United States Department of Justice (DOJ), announced the "Selection of Monitors in Criminal Division Matters" memorandum (the Benczkowski Memorandum). The Benczkowski Memorandum supplements the existing 2008 Selection and Use of Monitors in Deferred Prosecution Agreements and Non-Prosecution Agreements with Corporations (the Morford Memorandum) and replaces prior guidance issued in 2009 by then Assistant Attorney Gene... Read Full Post »

The Deerfield Settlement - Advisers Should Take Notice

Posted on October 17, 2017 at 11:30 AM

The recent SEC settlement involving Deerfield Management Company L.P. (“Deerfield”), a hedge fund and registered investment adviser, raises some interesting issues around the scope of an investment adviser’s duty to create and enforce policies and procedures. Deerfield paid approximately $4.6 million to settle SEC charges that it failed to create and enforce controls reasonably designed to prevent the misuse of material, nonpublic information in violation of Section 204A of ...

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