Part three of Cari’s Legal Exchange explores Foreign Corrupt Practices Act (FCPA) enforcement, regulatory agency crossover, and the challenges of delisting from government sanctions lists. 

In part one of Cari’s Legal Exchange, Cari Stinebower and partner and former U.S. Attorney for the District of Columbia Matt Graves discuss how companies can navigate evolving DOJ voluntary disclosure programs, the importance of compliance, and the growing focus on individual accountability in corporate investigations.

On June 23, 2025, the first-ever prosecution for bad-faith use of 10b5-1 trading plans resulted in Terren Scott Peizer, the former CEO and executive chairman of the publicly traded company Ontrak, Inc., being sentenced to 42 months in prison and ordered to pay $17.9 million in fines and restitution. A California federal district court found that Peizer had entered into Rule 10b5-1 plans in bad faith and while in possession of material nonpublic information to avoid more than $12.5 million in losses related to the termination of a large customer contract.