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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.

PCCE is directed by faculty director Jennifer Arlen '86. Through 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.

From the PCCE Blog, Compliance & Enforcement

Accounting Fraud 2.0: Increased Enforcement Activity Based on Non-GAAP Metrics

by Arthur Greenspan, Jakob Sebrow, James Walker, and David Massey Accounting fraud has long been a staple of the enforcement program at the U.S. Securities and Exchange Commission (SEC) and the U.S.… more

New York Department of Financial Services Emergency Regulations — Mandatory Forbearances for Residential Mortgage Loans

by Mylan L. Denerstein, Matthew L. Biben, James L. Hallowell, Mitchell A. Karlan, Arthur S. Long, and Emil N. Nachman On March 21, 2020, New York Governor Andrew Cuomo issued an Executive Order… more

How the SEC Enforcement Division Responds to a Crisis

by Martine M. Beamon, Robert A. Cohen, Joseph A. Hall, Gary Lynch, Neil H. MacBride, Stefani Johnson Myrick, Paul J. Nathanson, Annette L. Nazareth, Linda Chatman Thomsen, and Kenneth L. Wainstein As… more

Controlling Material, Non-Public Information During the Coronavirus Pandemic

by John F. Savarese, Wayne M. Carlin, and David B. Anders  In an unusual statement issued earlier this week, the Co-Directors of the SEC’s Division of Enforcement, Stephanie Avakian and… more

Insider Trading Issues Raised by News of Senators’ Reported Trades

by Stephen L. Ascher, Charles D. Riely, and Jeremy H. Ershow As the world coped with the Coronavirus (COVID-19) pandemic, news spread that four senators made well-timed sales of well-chosen… more

COVID-19: Three Data Protection Tips for the EU and the UK

by Jeremy Feigelson, Avi Gesser, Jane Shvets, Ariane Fleuriot, Fanny Gauthier, Robert Maddox, and Dr. Friedrich Popp As businesses adapt to the COVID-19 pandemic, the challenges of managing a remote… more

FinCEN Guidance in Response to COVID-19

by Elizabeth Davy, Eric J. Kadel, Jr., Sharon Cohen Levin, Shari Leventhal, and John Grein Background On March 16, 2020, the Financial Crimes Enforcement Network (“FinCEN”) issued guidance (the… more

COVID-19 and the Compliance Risks Related to Sales and Marketing Practices

by Jennifer Kennedy Park and Jonathan Kelly The World Health Organization has now declared COVID-19 a pandemic, and as more businesses begin to face the impacts of quarantines and travel restrictions… more

OFAC Cites the Use of U.S.-Origin Software and U.S. Network Infrastructure in Reaching a Nearly $8 Million Settlement with a Swiss Commercial Aviation Services Company

by H. Christopher Boehning, Jessica S. Carey, Christopher D. Frey, Michael E. Gertzman, Roberto J. Gonzalez, Brad S. Karp, Rachel M. Fiorill, Karen R. King and Jacob A. Braly On February 26,… more

FINMA Imposes Measures and Sanctions on Julius Baer for Serious Anti-Money Laundering Failings

by Jonathan J. Rusch Since December 2018, the Swiss Financial Market Supervisory Authority (FINMA) has taken a series of significant actions that stress its concern about compliance by Swiss… more