Corporate Compliance Insights – Of the nine enforcement cases CCI examined where companies received credit for timely disclosure, only two included a measurable time window. In several others, the timeliness clock had effectively run out before the company acted — a whistleblower, a press report, or a parallel investigation had already answered the question. CCI editorial director Jennifer L. Gaskin examines what the enforcement record actually says about one of corporate compliance’s most consequential — and least defined — obligations.
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What the Enforcement Record Says About ‘Timely’ Disclosure
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