David Smyth on Compliance

Ralph Lauren Escapes FCPA Problems with Minimized Damage

Often, enforcement officials at the SEC and the Justice Department express their wish that securities law violators own up to their (mis)conduct as soon it comes to light. That is, come to the government and explain what has...more

4/23/2013 - Bribery Compliance Customs Damages DOJ FCPA Ralph Lauren SEC Self-Reporting

SEC Highlights Compliance and Ethics for Broker-Dealers

On Tuesday the SEC held a National Compliance Outreach Program for Broker-Dealers at an open meeting at its D.C. headquarters. The first panel – titled The Role of Compliance and Ethics – was nominally targeted to...more

4/11/2013 - Broker-Dealer Chief Compliance Officers Company Culture Compliance FCPA Risk Management SEC

SEC Enforcement Coming to a Private Equity Firm Near You

Bruce Karpati, chief of the SEC’s Asset Management Unit (“AMU” or the “Unit”), recently spoke at the Private Equity International Conference in New York, and opened a window into the Unit’s views toward the industry. In...more

3/5/2013 - AMU Asset Management Compliance Private Equity SEC

SEC’s Asset Management Unit Focuses on Compliance Failures, Vol. 2

As we discussed last month, the SEC’s Asset Management Unit has developed a likeness for not just big, headline-grabbing cases, but relatively small compliance-based cases that are designed to prevent minor problems from...more

12/19/2012 - Asset Management Unit Books & Records Compliance Investment Adviser Registration SEC

FCPA Declination Opinions? SEC and DOJ Sort of Have Them

The Justice Department and the SEC released long-awaited joint guidance on enforcement and compliance with the Foreign Corrupt Practices Act yesterday. Many have pointed out that the guidance does not cover much new ground...more

11/16/2012 - Compliance DOJ FCPA FCPA Resource Guide SEC

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