Kim Nemirow

Kim Nemirow

Ropes & Gray LLP

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Latest Publications


Mexico Enacts a Sweeping New Anti-Corruption Regime, Accompanied by a Public Apology from President Peña Nieto and Increased...

After an aggressive grassroots campaign, Mexican President Enrique Peña Nieto recently announced the enactment of sweeping changes to Mexico’s anti-corruption regime. The new law is a significant step toward transparency in a...more

8/17/2016 - Anti-Corruption Conflicts of Interest Enrique Pena Nieto Government Contractors Mexico New Regulations Transparency

Anti-Corruption Laws and Other International Risks – What it Means for the Real Estate Industry and How to Protect against Risks

Bribery, money laundering, and sanctions are key international risk areas for any global business, particularly those investing or operating in high-risk jurisdictions and industries. In addition to meaningful enforcement...more

8/12/2016 - Anti-Corruption Anti-Money Laundering Compliance Economic Sanctions Enforcement Authority FinCEN Geographic Targeting Order Real Estate Companies Real Estate Professionals

Akamai Technologies, Inc. and Nortek, Inc. Receive First Declinations Under the DOJ’s FCPA Pilot Program and Rare NPAs from the...

On June 7, 2016, the U.S. Department of Justice (“DOJ”) issued the first public declinations of a criminal enforcement action since implementing its new enforcement plan for the Criminal Division – Fraud Section’s Foreign...more

6/8/2016 - Akamai Technologies Declination DOJ Enforcement Actions FCPA Federal Pilot Programs Non-Prosecution Agreements Nortek

Novartis Agrees to Settle Bribery Charges Against Chinese Subsidiaries for $25 Million

On March 23, 2015, Swiss-based pharmaceutical company Novartis AG (“Novartis”) reached a civil settlement with the United States Securities and Exchange Commission (“SEC”) for violating the internal controls and books and...more

4/5/2016 - Enforcement Actions FCPA Non-Judicial Settlement Agreements Novartis Pharmaceutical Industry Popular SEC Subsidiaries

The Future of Chinese Enforcement: From Corruption to AML?

On February 17, 2016, the Spanish headquarters of the Industrial and Commercial Bank of China (“ICBC”) were raided by Europol officers and Spanish law enforcement authorities, on orders of a Spanish judge investigating the...more

3/4/2016 - Anti-Money Laundering China Criminal Prosecution Europol Money Transfer People's Bank of China Spain Strategic Enforcement Plan

SEC Charges U.S. Pharmaceutical Company for FCPA Violations Arising from Alleged Bribery in China

On February 4, 2016, the U.S. Securities and Exchange Commission (“SEC”) announced a settlement with U.S. pharmaceutical company SciClone Pharmaceuticals, Inc. (the “Company”) to resolve FCPA charges arising from its...more

2/17/2016 - Bribery Corporate Counsel Enforcement Actions FCPA Pharmaceutical Industry SEC

SEC Charges Australian Mining Company for FCPA Violations Arising from Its Hospitality Program at the 2008 Beijing Olympics

On May 20, 2015, the U.S. Securities and Exchange Commission (“SEC”) announced a $25 million settlement with Australian mining company BHP Billiton (the "Company") to resolve Foreign Corrupt Practices Act (“FCPA”) charges...more

5/21/2015 - Australia Bribery China Corporate Counsel Enforcement Actions FCPA Government Officials Olympics SEC

SEC Charges Underwriter and Bankers in Connection with Offering by China-based Issuer A Cautionary Tale of How Bad Facts and Weak...

On March 27, 2015, the U.S. Securities and Exchange Commission (SEC) announced charges against an investment bank and two of its bankers for failing to adequately review and escalate a due diligence report which contradicted...more

4/1/2015 - China Compliance Due Diligence Enforcement Actions Foreign Investment Investment Banks Public Offerings SEC Underwriting

China’s National Auditing Office Notes Compliance Concerns with Sponsorship of Academic Conferences in the Healthcare Sector

In China, it is common industry practice for pharmaceutical companies to sponsor academic conferences. As long as such events are aimed at enhancing the practice of medicine and patient welfare, the practice has been allowed....more

6/30/2014 - Audits China Healthcare Pharmaceutical Industry Popular Sponsors

U.S. Administrative Law Judge Suspends Chinese Affiliates of “Big Four” Accounting Firms

In a surprising turn in the long-running and widely reported dispute between the Securities and Exchange Commission (“SEC”) and the Chinese affiliates of the “Big Four” accounting firms, on January 22, 2014, a U.S....more

1/24/2014 - Accounting Audits China Compliance Enforcement Actions Foreign Affiliates Investigations SEC

Chinese Securities Regulator Announces Plans to Produce Documents in Ongoing “Big Four” Accounting Firm SEC Enforcement Action

According to a public statement issued by the China Securities Regulatory Commission (“CSRC”) on July 9, 2013, China’s securities regulator is preparing to hand over the audit documents of a U.S.-listed Chinese company to the...more


SEC’s Cross-Border Working Group Continues to Target China-Based Issuers

Introduction - A pair of recent enforcement actions brought by the U.S. Securities and Exchange Commission (the “SEC”) reflect the SEC’s continued focus on China-based issuers listed in the U.S. In the most recent case...more

6/27/2013 - China Cross-Border Enforcement Actions Fraud Investors IPO Misrepresentation SEC

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