Before she sought comments from the general counsel who flanked her, Grace Lamont, a partner at PriceWaterhouseCoopers, established the scene.

  • The Securities and Exchange Commission is flexing its muscles, committed (it says) to aggressive enforcement.
  • The new finance reform bill — once the Senate and House agree on one — is going to arm the SEC with whistleblower rewards that will likely inspire a flood of fraud tips.
  • The commission also plans to use nonprosecution agreements and deferred prosecution agreements, which will likely further ramp up the number of cases.

So, said Lamont, addressing the audience of in-house lawyers as well as the two GCs on the podium at the 22nd Annual General Counsel Conference in New York, “the environment that we have now presents companies and their officers with a heightened risk.” What should they be doing?

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