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ARTICLE · 03 FEBRUARY 2010

The SEC Steps Up Enforcement Efforts: The Enforcement Cooperation Initiative

Jones Day
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On January 13, 2010, the SEC continued its efforts to put pressure on companies and individuals to come forward with evidence of potential violations of the federal securities laws.

United StatesCriminal Law
Jones Day
Jones Day
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Jocelyn Kelly
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Jonathan Leiken
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On January 13, 2010, the SEC continued its efforts to put pressure on companies and individuals to come forward with evidence of potential violations of the federal securities laws. The SEC announced its adoption of the Enforcement Cooperation Initiative (the "Initiative"), a formal framework for witness cooperation that is modeled closely on the program used by federal prosecutors in federal criminal cases. The program includes cooperation agreements, deferred prosecution agreements, and nonprosecution agreements—tools used for decades by federal prosecutors in persuading corporations and individuals to cooperate against others.

The Initiative also details the incentives for individuals to cooperate with enforcement officials by clarifying how the SEC will evaluate an individual's cooperation and offering immunity to some informers. Robert Khuzami, the head of SEC enforcement and a former federal prosecutor, explained in a statement that the program is designed to

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