Last week the SEC and Justice Department brought parallel FCPA enforcement actions charging Ohio-based Diebold, Inc., a global provider of ATMs and bank security systems.
From the SEC’s press release: “[S]ubsidiaries...more
Remember 1995? It was a long time ago, so you can be forgiven for not recalling much of it. To re-orient you: it was President Clinton’s first term; the Oklahoma City bombing happened in April; a jury found O.J. Simpson not...more
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
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
One of the salient features of the SEC’s enforcement program in recent years has been a dearth of accounting fraud cases. While those cases used to be the SEC’s bread and butter, and hovered around 200 actions per year, they...more
On December 17th, the SEC brought a settled administrative FCPA action against Allianz SE, a German insurance company with a subsidiary in Indonesia. The order does not allege violations of the FCPA’s antibribery provisions,...more
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