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“Pay to Play” Developments

Based on recent announcements from the SEC and its Staff, changes may be forthcoming for advisers’ use of third-party solicitors for government entity clients....more

7/29/2015

Fraudulent Receipts Pose Risks for Multinationals Operating in China

Multinational companies operating in the country should adapt their compliance programs in light of the risk of civil and criminal penalties. Fraudulent official receipts — or "fapiao"(the Chinese word for an official...more

SEC Warns About Exemptive Order Compliance

Division of Investment Management's guidance reminds firms to comply with conditions and representations in exemptive orders and notes that consequences for noncompliance may be "severe."...more

5/20/2013  /  Compliance , ETFs , Exemptive Orders , OCIE , OIG , SEC

SEC Settles Suit for Misleading Advisory Contract Approval Disclosure

Settlement with mutual fund directors and service providers serves as a reminder of responsibilities for disclosures relating to the approval of investment advisory contracts and provides insight into SEC enforcement...more

District Court Reinforces Broad Territorial Reach of the FCPA

Decision in Magyar Telekom case maintains that engaging in unlawful conduct abroad that is "directed toward the United States, even if not principally directed there," may trigger personal jurisdiction....more

Canadian Government Announces Proposed Amendments to Anticorruption Law

Amendments aim to improve enforcement of Canadian foreign corruption law by expanding jurisdiction, creating a books and records offense, eliminating the facilitation payments exception, redefining "business" and enforcement...more

Lanny Breuer Touts Robust, Transparent FCPA Enforcement

Assistant Attorney General Breuer highlights transparency, global trends, and the benefits of robust compliance programs at the American Conference Institute's 28th National Conference on the Foreign Corrupt Practices Act....more

11/26/2012  /  Compliance , DOJ , FCPA , SEC
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