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- 2023
- Working Paper
What Makes Managers’ Private Disclosures Informative? Evidence from Professional Investors
By: Michael Durney, Hoyoun Kyung, Jihwon Park and Eugene F. Soltes
- 2022
- Chapter
Corporate Misconduct’s Relevance to Society through Everyday Misconduct
By: Eugene Soltes
Terms like "corporate misconduct" and "white-collar crime" typically bring to mind major scandals like Enron or Bernie Madoff. This popular perception overlooks another important—and in fact much more typical—type of deviance: "everyday misconduct." Everyday misconduct...
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- 2022
- Book
Corporate Criminal Investigations and Prosecutions
By: Leo R. Tsao, Daniel S. Kahn and Eugene F. Soltes
Over the past two decades, corporate criminal liability has developed into one of the fastest-growing and most dynamic areas of legal practice. The growth of corporate criminal enforcement has correlated with a broad shift in how the government investigates and...
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- 2022
- Chapter
Measuring Compliance Risk and the Emergence of Analytics
By: Eugene F. Soltes
Corporate compliance manages a diverse set of regulatory and reputational concerns ranging from fraud to privacy to discrimination. However, effectively managing such risks has often been hampered by a lack of adequate information about when, where, and why misconduct...
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- December 2021
- Case
Should I Stay or Should I Go? Assessing Risk in Carlos Ghosn's International Escape
By: Eugene F. Soltes, Grace Liu and Muneeb Ahmed
In 2018, automotive tycoon Carlos Ghosn was arrested in Japan on financial misreporting charges, followed later by charges of improper payments and misappropriation of funds. Over a year later, still awaiting trial, Ghosn organized his escape from house arrest in Tokyo...
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- Article
Is ‘Not Guilty’ the Same as ‘Innocent’? Evidence from SEC Financial Fraud Investigations
By: Eugene F. Soltes and David H. Solomon
When the Securities and Exchange Commission (SEC) investigates firms for financial fraud, investors learn about the investigation only if managers disclose it, or regulators sanction the firm. We investigate the effects of such disclosures using confidential records on...
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- September 2020
- Case
An Introduction to Money Laundering: 'The Hunter'
By: Eugene Soltes, Guilhem Ros and Grace Liu
Money laundering schemes disguise the criminal origins of an estimated 2% to 5% of the world’s gross domestic product. Money laundering not only enables criminals to escape detection, but may also be used to finance further criminal operations including terrorism. This...
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- Article
Paper Versus Practice: A Field Investigation of Integrity Hotlines
By: Eugene Soltes
In an effort to motivate firms to more rapidly detect potential misconduct, legislators, regulators, and enforcement agencies incentivize firms to have integrity or “whistleblowing” hotlines. These hotlines provide individuals an opportunity to report alleged...
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- Winter 2020
- Article
Unsubstantiated Allegations and Organizational Culture
By: Eugene F. Soltes
When organizations investigate allegations of misconduct, they routinely determine that some allegations are unsubstantiated. A variety of factors may contribute to the conclusion that an allegation does not warrant substantiation, including a lack of supporting...
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- December 2019 (Revised November 2023)
- Background Note
Legal Analysis: Insider Trading Liability
By: Trevor Fetter, Eugene F. Soltes and Grant Wahlquist
There are numerous restrictions against trading on material, nonpublic information (MNPI)—typically called “insider trading.” This note describes the limitations facing managers and investors as enforced civilly and criminally within the United States.
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- 2019
- Article
The Frequency of Corporate Misconduct: Public Enforcement versus Private Reality
By: Eugene F. Soltes
Perceptions about the frequency of misconduct—among the public, academics and even
regulators—have largely been formed by examining enforcement statistics, which rely on the detection and sanctioning of the misconduct. This study aims to illuminate the real occurrence...
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- Article
Creating Firm Disclosures
By: Amir Amel-Zadeh, Alexandra Scherf and Eugene F. Soltes
Managers expend significant time and effort preparing disclosures about firm performance and strategy. Although prior literature has explored how variation in the style and presentation of disclosures impacts investors' perceptions of firms, little is known about how...
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- August 2019
- Teaching Note
Creating Accountability in Afghanistan
By: Jonas Heese, Gerardo Pérez Cavazos, Eugene F. Soltes and Grace Liu
Teaching Note for HBS No. 120-024.
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- August 2019
- Case
Creating Accountability in Afghanistan
By: Jonas Heese, Gerardo Pérez Cavazos, Eugene F. Soltes and Grace Liu
By early 2019, the United States had contributed $132 billion to the Afghan reconstruction. John Sopko, in his role as the Special Inspector General for Afghan Reconstruction (SIGAR), was in charge of providing accountability for U.S. aid funding. Sopko’s oversight...
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- July–August 2019
- Article
Where Is Your Company Most Prone to Lapses in Integrity?
By: Eugene F. Soltes
Every sizable organization has integrity gaps—areas where what’s considered appropriate behavior diverges from the norms set by its leaders. Within these pockets, things like offensive language, overly aggressive sales practices, or conflicts of interest may be...
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- May 2019
- Article
Who Consumes Firm Disclosures? Evidence from Earnings Conference Calls
By: Anne Heinrichs, Jihwon Park and Eugene F. Soltes
Using a set of proprietary records, we examine who consumes quarterly earnings conference calls and under which circumstances the calls are consumed. While there is significant interest in calls by institutional investors and sell-side analysts, we find that investors...
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- January 2019
- Teaching Note
Accenture's Code of Business Ethics
By: Eugene Soltes
Teaching Note for HBS No. 119-049.
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- January 2019
- Case
Accenture's Code of Business Ethics
By: Eugene Soltes
Leaders of Accenture’s compliance and ethics program are seeking to design a new code of business ethics for its global workforce of over 400,000 employees. The case explores the decision-making process that went into the design process and ultimately how they created...
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