Glen Kopp

Glen Kopp

Bracewell LLP

Contact  |  View Bio  |  RSS

Latest Publications

Share:

New York DFS Finalized Cybersecurity Regulations Go Into Effect March 1, 2017

On February 16, 2017, the New York State Department of Financial Services (DFS) announced the final version of the “first-of-its-kind” cybersecurity regulations governing financial institutions, insurance companies, and other...more

3/3/2017 - Banks CISO Corporate Governance Covered Entities Customer Protection Rule Cybersecurity Department of Financial Services Financial Institutions Insurance Industry NYDFS Popular Risk Assessment

DOJ Releases New Guidance on Compliance Programs

On February 8, 2017, the Fraud Section of the Department of Justice (“DOJ”) quietly published pointed and specific guidance on how it assesses – and intends to assess – compliance programs in a report titled “Evaluation of...more

2/23/2017 - Compliance Corporate Governance Corporate Misconduct Criminal Investigations DOJ Enforcement Actions FCPA Federal Sentencing Guidelines Fraud Alerts

SEC's New Rule Requires Additional Disclosures on Form ADV

On January 12, 2017, the SEC’s Office of Compliance Inspections and Examinations (“OCIE”) published its 2017 examination priorities.1 OCIE’s 2017 priorities, which largely mirror its 2016 priorities, cover three areas: (1)...more

1/30/2017 - Broker-Dealer Compliance Conflicts of Interest Cybersecurity Elder Issues Fiduciary Duty FINRA Investor Protection OCIE Policies and Procedures Public Pension Retail Investors Retirement SEC SEC Examination Priorities Stress Tests

Modern Enforcement: Rolls-Royce’s $800 Million Global Settlement

Rolls-Royce plc, a UK-based company that manufactures engines and generators for the aerospace, defense, marine, and energy sectors, has agreed to pay over $800 million to resolve parallel investigations by U.S., UK, and...more

1/27/2017 - Automotive Industry Brazil Bribery Corruption Deferred Prosecution Agreements DOJ Enforcement Actions FCPA Government Officials Oil & Gas Pipelines Rolls-Royce SFO UK UK Bribery Act

FINRA Fines Lincoln Financial Sub $650,000 For Cybersecurity Shortcomings

A Lincoln Financial Group subsidiary agreed to pay $650,000 to the Financial Industry Regulatory Authority (FINRA) to resolve allegations that it failed to implement sufficient security policies to protect confidential...more

11/23/2016 - Broker-Dealer Cloud Storage Customer Information Cybersecurity Enforcement Actions FINRA Policies and Procedures Regulation S-P Supervision

Federal Regulators Unveil Proposed Cybersecurity Standards for Large Financial Firms

On October 19, 2016, federal regulators issued an Advance Notice of Proposed Rulemaking titled “Enhanced Cyber Risk Management Standards.” The draft standards, jointly released by the Federal Reserve, the Federal Deposit...more

11/21/2016 - Advanced Notice of Proposed Rulemaking (ANPRM) Banking Industry Regulations Banks Covered Entities Critical Infrastructure Sectors Cybersecurity FDIC Federal Reserve Financial Institutions Governance Standards OCC Proposed Amendments Public Comment Risk Management

New York DFS Announces New Proposed Cybersecurity Regulations

On September 13, 2016, the New York State Department of Financial Services (“DFS”) released proposed cybersecurity regulations for financial institutions.1 When the regulations become effective, they will make New York the...more

9/28/2016 - Banks Covered Entities Cybersecurity Department of Financial Services Financial Institutions Insurance Industry Mortgage Lenders Proposed Regulation

SEC's New Rule Requires Additional Disclosures on Form ADV

On August 25, 2016, the SEC adopted Release No. IA-4509 (the “New Rule” or the “amendments”) that amends Form ADV to increase the amount of information that registered investment advisors (“Advisors”) must disclose to the...more

9/21/2016 - Disclosure Requirements Filing Requirements Form ADV Investment Adviser Reporting Requirements SEC SMAs Social Media Account Ownership

Advisory Firms Fined for Disseminating Misleading Performance Claims Made by Another Firm

On August 25, the U.S. Securities and Exchange Commission announced fines against 13 investment advisory firms for distributing false claims originally made by F-Squared Investments. In a prior SEC enforcement case, F-Squared...more

9/16/2016 - Enforcement Actions Investment Adviser Investors SEC

Proposed Rule Relates to Investment Advisers' Business Continuity and Transition Plans

The Securities and Exchange Commission (“SEC”) recently proposed Rule 206(4)-41 under the Investment Advisers Act of 1940 (“Advisers Act”), which would require registered investment advisers (“firms” or “Advisors”) to adopt...more

7/21/2016 - Business Continuity Plans Duty of Care Duty of Loyalty Guidance Update Investment Adviser Proposed Rules SEC

Second Circuit Rules that Federal Warrants Do Not Apply to Electronic Information Stored Overseas

On July 14. 2016, the Second Circuit ruled that the government cannot lawfully use a search warrant to compel access to consumer data stored by Microsoft Corporation (Microsoft) overseas. In its decision, the court overturned...more

7/19/2016 - Contempt Electronically Stored Information Email Extraterritoriality Rules Ireland Microsoft Motion to Quash Reversal Search Warrant Stored Communications Act

DOJ Announces First Declinations After Implementing FCPA Pilot Program

The U.S. Department of Justice (DOJ) issued its first set of public declinations since its April unveiling of a new self-reporting Foreign Corrupt Practices Act (FCPA) pilot program. On June 7, 2016, Akamai Technologies,...more

6/10/2016 - Bribery China Disgorgement DOJ FCPA Federal Pilot Programs Non-Prosecution Agreements Popular SEC Voluntary Disclosure

DOJ Launches FCPA Pilot Program to Promote Company Self-Reporting

In a speech delivered last Wednesday by Assistant Attorney General Leslie Caldwell, the Justice Department’s (“DOJ”) Criminal Division announced the launch of a new Foreign Corrupt Practices Act (“FCPA”) “pilot program” that...more

4/13/2016 - Cooperation Criminal Prosecution DOJ FCPA Federal Pilot Programs Federal Sentencing Guidelines Personal Liability Remediation Self-Reporting Voluntary Disclosure

Improved U.S. - Cuba Relations Create Potential FCPA Risks for U.S. Companies Looking to Do Business There

The normalization of relations between the United States and Cuba offers potential lucrative business opportunities for companies that are prepared to meet Cuba’s unique corruption risks. On December 17, 2014, President...more

4/7/2016 - Bribery Corporate Counsel Cuba FCPA Foreign Official TCPI Young Lawyers

Supreme Court Rules Against Freezing "Untainted" Assets

In a ruling that could have far-reaching implications for criminal defendants’ right to counsel of their choice, the Supreme Court decided on March 30, 2016 that the government cannot freeze “untainted” assets that are not...more

3/31/2016 - Asset Freeze Criminal Prosecution Luis v United States Right To Counsel SCOTUS Sixth Amendment White Collar Crimes

VimpelCom's Global FCPA Settlement - A Multinational Resolution

The U.S. Department of Justice (DOJ), the U.S. Securities and Exchange Commission (SEC) and the Public Prosecution Service of the Netherlands (OM) announced a coordinated criminal and civil Foreign Corrupt Practices Act...more

2/26/2016 - Bribery Compliance Deferred Prosecution Agreements DOJ Enforcement Actions FCPA SEC Settlement Telecommunications VimpelCom

SEC and Hitachi Reach FCPA Settlement Over Corrupt Payments in South Africa

The U.S. Securities and Exchange Commission (SEC) recently announced a settlement with Hitachi, Ltd. over allegations that the company sold shares in a South African subsidiary to a front company for the African National...more

10/9/2015 - Bids Bribery Conflicts of Interest FCPA Federal Contractors Hitachi SEC South Africa

SEC Announces First Cybersecurity Enforcement Action Against an Investment Adviser for Failure to Protect Client Data

On September 22, 2015, the Securities and Exchange Commission (SEC) announced its first cybersecurity-related enforcement action against an investment adviser for failure to protect customer records and information. According...more

10/1/2015 - Cybersecurity Enforcement Actions Investment Adviser Personally Identifiable Information Privacy Policy Registered Investment Advisors SEC Settlement

SEC: 2015 Examination Priorities – Cybersecurity Compliance and Controls

Registered broker-dealers and investment advisers received a stern warning to strengthen their cybersecurity programs or face further regulatory scrutiny. On September 15, 2015, the SEC announced a plan to sharpen its focus...more

9/21/2015 - Broker-Dealer Compliance Cybersecurity Data Breach Data Loss Prevention Incident Response Plans Investment Adviser OCIE Risk Assessment SEC SEC Examination Priorities Vendors

DOJ: Companies, Serve Up Your Executives!

On September 9, 2015, the Department of Justice (“DOJ”) issued an internal memorandum regarding individual accountability for corporate wrongdoing. The memo, authored by Deputy Attorney General Sally Quillian Yates, is aimed...more

9/11/2015 - Attorney Generals Corporate Executives Corporate Fraud Corporate Liability Criminal Investigations Criminal Prosecution DOJ Government Investigations Personal Liability White Collar Crimes

DOJ Sets its Sights on Antitrust Violations in the E-Commerce Marketplace

The Antitrust Division of the U.S. Department of Justice (Antitrust Division) continues to intensify and expand criminal enforcement of the antitrust laws. The results speak for themselves. In fiscal year 2014, the Antitrust...more

5/13/2015 - Antitrust Division Antitrust Violations Corporate Criminal Fines Criminal Antitrust Litigation Criminal Prosecution DOJ E-Commerce Penalties Popular Price-Fixing

Greater Good Adds More Complexity for Contractors in the Middle East

On January 29, 2014, the Federal Acquisitions Regulations Council published the final rule amending the Combating Trafficking in Persons for U.S. government contracts (the "Anti-Human Trafficking Rule"). The Anti-Human...more

2/4/2015 - Federal Acquisition Regulations (FAR) Federal Contractors Final Rules Human Trafficking Middle East TCN

Second Circuit Overturns Insider Trading Convictions of Two Portfolio Managers

In a blow to the Southern District of New York’s impressive run of insider trading convictions, the United States Court of Appeals for the Second Circuit held yesterday that insider trading convictions require the government...more

12/12/2014 - Hedge Funds Illegal Tipping Insider Trading Material Nonpublic Information Portfolio Managers Securities Securities Fraud US v Newman

S.D.N.Y. Issues Spoliation Sanctions Against Foot Locker

The sanctions recently levied against Foot Locker serve as a potent reminder that understanding data and document preservation requirements is imperative. A New York federal judge issued sanctions against Foot Locker last...more

7/25/2014 - Corporate Counsel Data Protection Discovery Document Productions Document Retention Policies Evidence Negligence Retailers Sanctions Spoliation

D.C. Circuit Court Clarifies Scope of Attorney-Client Privilege in Internal Investigations

On June 27, 2014, the United States Court of Appeals for the District of Columbia Circuit issued an opinion clarifying the application of the attorney-client privilege in internal investigations. ...more

7/8/2014 - Attorney-Client Privilege Federal Rules of Civil Procedure Internal Investigations Work Product Privilege

26 Results
|
View per page
Page: of 2

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:

Sign up to create your digest using LinkedIn*

*By using the service, you signify your acceptance of JD Supra's Privacy Policy.

Already signed up? Log in here

*With LinkedIn, you don't need to create a separate login to manage your free JD Supra account, and we can make suggestions based on your needs and interests. We will not post anything on LinkedIn in your name. Or, sign up using your email address.
×