BUSINESS LAW IN THE PUBLIC INTEREST

The NYU Program on Corporate Compliance and Enforcement (PCCE) is a law and research program dedicated to developing a richer and deeper understanding of the causes of corporate misconduct and the nature of effective enforcement and compliance.

"In the few years since its launch, the Program on Corporate Compliance and Enforcement has made its mark here in New York and in the legal profession across the country.  You have provided a much needed venue to explore both the causes of and potential solutions to corporate misconduct."
DAG Sally Quillian Yates speaking at NYU on September 10, 2015

PCCE is directed by faculty co-directors Jennifer Arlen '86 and Geoffrey Miller and executive director Serina M. VashThrough practical discourse and legal scholarship, PCCE seeks to help shape optimal enforcement policy, guide firms in developing more effective and robust compliance programs, and enhance education in the field of corporate compliance and enforcement. Each year, several students are accepted into the program, enabling them to gain unparalleled expertise in this area, both through courses and through access to leading practitioners. No other leading law school offers the same depth and breadth of courses by full-time faculty in this area.

Read Mission Statement

Chair of the U.S. Securities and Exchange Commission Mary Jo White Addresses a New Model for SEC Enforcement

November 18, 2016
Greenberg Lounge | 11:30 AM - 12:30 PM

Read text of Chair Mary Jo White's addresses here.

Recent Events

PCCE Spring Conference:
Expanding Individual Accountability for Corporate Misconduct

Friday, March 31, 2017 | Lester Pollack Colloquium Room
Registration Required

This conference brought together academics, enforcement officials, general counsel, compliance officers, and white collar defense lawyers to discuss the evolving and optimal scope of individual liability for corporate misconduct. The conference focused on efforts to hold senior executives accountable for crimes by those under them.

Keynote Speaker: Mark Steward, Director of Enforcement and Market Oversight, Financial Conduct Authority, U.K.

View Mark Steward's speech here.

Opening Discussion:
Why Do They Do It?
: Eugene Soltes, Jakurski Family Associate Professor of Business Administration, Harvard Business School

Panel Discussions Included:

  • External Liability and Internal Sanctions for Supervisors
  • Empirical Analysis of Securities Fraud Enforcement
  • Responsible Corporate Officer Doctrine Liability with Enhanced Sanctions
  • Corporate Investigations After the Yates Memo

PCCE Lunch and Learn Series Presents:
Climbing the Corporate Ladder: Start Planning Now to be a Successful General Counsel

Wednesday, April 19, 2017  |  12:00 PM - 2:00 PM
40 Washington Square South New York, NY 10012  
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The panel consists of Michael Neus (former GC of Perry Capital), Steve Kessler, (formerly General Counsel, Goldman Sachs); Emily Locher, (General Counsel, Summit Rock Advisors); Stuart Rubin, (Former General Counsel of FLAG TELECOM).


Cybersecurity Risk and Regulation with Zachary K. Goldman, Thomas Harrington, Marshall L. Miller, and Scott Sarafian

Moderated by PCCE Executive Director Serina M. Vash

February 15, 2017
Lester Pollack Colloquium  | 6:00 PM – 8:00 PM  | Registration Required

On February 15, 2017, the NYU Program on Corporate Compliance and Enforcement hosted an in depth discussion about the realities of Cybersecurity Risk and Regulation.  Join us as the following four experts begin the discussion with a look at NYDFS’ Cybersecurity Requirements for Financial Services Companies, 23 NYCRR Section 500:

  • Zachary K. Goldman, Executive Director, Center on Law & Security and Co-Founder of the Center for Cybersecurity

  • Thomas Harrington, Managing Director and Chief Information Security Office at Citi, and former Associate Deputy Direct of the FBI

  • Marshall L. Miller, Of Counsel, Wachtell, Lipton, Rosen & Katz, and former Principal Deputy Assistant Attorney General & Chief at the U.S. Department of Justice's Criminal Division

  • Scott Sarafian, Supervisory Special Agent, United States Secret Service, Electronic Crimes Task Force - NYC

The panel discussed the impending implementation of the NYDFS' new cybersecurity rule, its potential impact on the financial sector from the vantage points of both compliance with and enforcement of the new cybersecurity requirements, the federal governments’ anticipated Enhanced Cyber Risk Management Standards, and the realities of whether piecemeal cybersecurity programs can keep companies and their information secure.

The panel, moderated by Serina M. Vash, Executive Director of PCCE, was followed by a Q & A Session.

Insider Trading Enforcement in the Wake of Salman

Moderated by Jennifer Arlen, Norma Z. Paige Professor of Law, NYU School of Law

December 20, 2016
Lester Pollack Colloquium  | 6:20 PM – 8:00 PM  | Registration Required

A panel of insider trading experts including Antonia Apps, Partner Milbank, Tweed, Hadley & McCloy LLP; Greg Morvillo, Partner Morvillo LLP; Michael Neus, Managing Partner and General Counsel, Perry Capital, LLC; and Winston Paes, Chief, Business and Securities Fraud Section U.S. Attorney's Office, Eastern District of New York, examined the impact of the Supreme Court’s December 6, 2016 decision in Salman v. United States on insider trading enforcement policy and will look at the state of the law in the wake of the High Court’s decision.

Wading Into the Gray: Compliance and Enforcement Lessons When Good People Make Bad Decisions
A Panel with Rashmi Airan, Richard Bistrong, Walt Pavlo, and FBI SSA William McMurry

November 30, 2016
Lester Pollack Colloquium  | 5:00 PM – 7:00 PM  | Registration Required

On November 30, 2016, the NYU Program on Corporate Compliance and Enforcement hosted Rashmi Airan, Richard Bistrong, and Walt Pavlo, for a discussion on the experiences that resulted in their own federal criminal convictions for white collar crimes, with additional insights from FBI SSA William McMurry.  The panel will identify inflection points in law and business decision making and compliance processes where questions, interventions, knowledge or relationships could have helped them make better, more ethical decisions.

The panel, moderated by Serina M. Vash, Executive Director of PCCE.

October 21, 2016 Fall Conference
Compliance: New Risks, Challenges, and Approaches

Lester Pollack Colloquium Room  | 9:00 AM – 4:15 PM | Registration Required

Keynote Address:



DFS’s Contributions to Fostering a Compliance Culture in an Age of Risk 
Maria T. Vullo, Superintendent, New York State Department of Financial Services

Click HERE for the Full Conference Agenda.

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April 8, 2016:  Conference on Corporate and Individual Liability for Corporate Misconduct After the Yates Memo

The PCCE Spring Conference brought together enforcement officials, academics, white collar defense lawyers, judges, and other prominent members of the bar for an invitation-only event to discuss the evolution, efficacy and future of corporate criminal enforcement policy for individuals and firms, both in the United States and abroad. PCCE Conference Rules applied.  By Invitation Only. Map It

Keynote Speaker:  Director David Green of the Serious Fraud Office (UK)
Conference OrganizerJennifer Arlen

View Director Green's Keynote Speech Here
View Conference Agenda Here 

January 21, 2016
Roundtable Discussion with Virginia Romano, Joyce Branda, and Sung-Hee Suh of the United States Department of Justice
Lester Pollack Colloquium  | 4:00 PM – 6:00 PM  | By Invitation Only

On January 21, 2015, the NYU Program on Corporate Compliance and Enforcement hosted Virginia Romano, Joyce Branda, and Sung-Hee Suh of the United States Department of Justice for an invitation-only discussion on corporate compliance and enforcement policy in light of the September 2015 DAG Yates Memo on individuality liability in corporate criminal misconduct.  This invitation-only panel brought together leaders in the compliance and enforcement worlds—academics, compliance officials, general counsels, government officials, defense lawyers and judges.

The presentation by Ms. Romano, Ms. Branda and Ms. Chen was followed by a Q & A Session – all of which was  governed by Chatham House Rule, modified to allow the taking of photograpghs.

November 13, 2015
Roundtable Discussion with Chief Andrew Weissmann and the New Compliance Counsel Hui Chen of the DOJ's Criminal Division Fraud Section
Lester Pollack Colloquium  | 12:30 PM – 2:00 PM  | By Invitation Only

The NYU Program on Corporate Compliance and Enforcement hosted Andrew Weissmann, Chief of the Fraud Section, Criminal Division, Department of Justice and the new Compliance Counsel for the Fraud Section for an invitation-only discussion on corporate compliance and enforcement policy and the role of DOJ’s new compliance counsel in corporate criminal enforcement.  View Video Here (Publicly Available Portion Only).

Read Fraud Section Statement on Hiring Hui Chen As New Compliance Counsel.  
View AAG Leslie Caldwell's Remarks on DOJ's New Compliance Counsel

The initial discussion is publicly available and was followed by a question and answer session under Chatham House Rule.

September 29, 2015:  An Address by the President of Paraguay His Excellency Horacio Cartes
Lipton Hall  | 10:00 AM – 11:00 AM 

Together with NYU President John Sexton and the Center for Latin American and Caribbean Studies, the Program on Corporate Compliance and Enforcement  was pleased to welcome His Excellency Horacio Cartes to New York University for an address entitled, "Introducing Paraguay: A Land of Opportunity." President Cartes discussed crucial reforms promoted by his Administration on : (i) poverty reduction and social inclusion, (ii) anti-corruption, public sector transparency and accountability; and (iii) Paraguay’s openness to the global economy.  President Cartes also discussed Paraguay’s potential to become a business and industrial hub in Latin America and President Cartes’ groundbreaking educational initiative.  View President Cartes Speech Here (Spanish Version).

September 10, 2015:  US DOJ Issues New Guidelines on Individual Accountability for Corporate Wrongdoing
Greenberg Lounge | 12:45 PM – 1:45 PM 

Deputy Attorney General Sally Quillian Yates announced new DOJ guidelines on individual accountability for corporate wrongdoing on September 10, 2015 at NYU School of Law in Greenberg Lounge.  The Program on Corporate Compliance and Enforcement hosted her address.    
Read More News on DAG Yates' Announcement.

The September 9, 2015 Yates Memo can be viewed here.  
Text of DAG Yates' Remarks can be viewed here.  
View Photo Gallery of Yates Reception Here.

 

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