David Smyth on FCPA

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

Accounting Fraud Not Just for Public Companies Anymore

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

4/4/2013 - Accounting Fraud Disclosure Requirements FCPA Investment Advisers Act of 1940 Oppenheimer & Co. SEC

SEC Charges Allianz with FCPA Violations

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

1/2/2013 - Allianz Books & Records FCPA SEC Subsidiaries Voluntary Disclosure Whistleblowers

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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