Patrick Robbins

Patrick Robbins

Shearman & Sterling LLP

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Gifts of Travel and Luxury Watches to Saudi Officials Not Mere 'Icing on the Cake' for FCPA Charges

Improper Gifts Alone, Without Cash Bribes, Serve as Basis for SEC’s Latest FCPA Enforcement Action - Earlier this week, the SEC announced fines for two former defense contractor employees for FCPA violations relating...more

11/21/2014 - Bribery Conditional Gifts Enforcement Actions FCPA Foreign Official Popular Saudi Arabia SEC

SEC Settlement with Layne Christensen Raises New Questions on the Government’s Understanding of the Business Nexus Element of the...

Last week the SEC settled charges against Layne Christensen for various violations of the FCPA. While a relatively unremarkable case at first glance, the SEC’s charges against Layne Christensen reflect a troubling approach by...more

11/5/2014 - Cease and Desist Orders Consent Order Construction Industry FCPA Layne Christensen Co SEC Subsidiaries

Securities Enforcement 2014 Mid-Year Review

While not nearly as transformative and dramatic as the first half of 2013 and the early days of Chair Mary Jo White and Director of Enforcement Andrew Ceresney, the first six months of 2014 was just as busy and productive...more

8/1/2014 - Citigroup Enforcement Enforcement Actions Judge Rakoff Neither Admit Nor Deny Settlements SEC Settlement

Supreme Court Preserves 'Fraud-on-the-Market' and Validates Use of 'Price Impact' Defense Against Class Certification in...

In its long-awaited decision in Halliburton Co. v. Erica P. John Fund, Inc. (“Halliburton II”), the US Supreme Court upheld the validity of the fraud-on-the-market presumption set forth in Basic Inc. v. Levinson, 485 US 224...more

6/27/2014 - Basic v Levinson Class Action Class Certification Fraud Fraud-on-the-Market Halliburton Halliburton v Erica P. John Fund SCOTUS Securities Fraud

So You Want to See Messi, Neymar, Ronaldo, and Xavi: Brazil Issues Directive Barring Government Officials From Receiving World Cup...

Earlier today, the Office of the Comptroller General in Brazil, Controladoria-Geral da União (“CGU”), issued a sweeping directive barring government officials from accepting offers to attend or participate in the upcoming...more

6/3/2014 - Brazil Compliance FCPA Government Officials Public Officials UK UK Bribery Act World Cup

DOJ Scores First Antitrust Extradition: More to Come?

With Friday’s announcement of the first-ever extradition of a foreign executive on criminal antitrust charges to the United States, the US Department of Justice has won a major victory in its effort to prosecute and deter...more

4/8/2014 - Antitrust Litigation DOJ Extradition

SEC Enforcement Year in Review - 2013

Marked by leadership changes, high-profile trials, and shifting priorities, 2013 was a turning point for the Enforcement Division of the Securities and Exchange Commission (the “SEC” or the “Commission”). While the results of...more

1/9/2014 - Accounting Fraud Auditors Bribery Broker-Dealer China Deferred Prosecution Agreements Disclosure Dodd-Frank Enforcement Actions FCPA FIRREA Injunctions Insider Trading Investment Adviser Mary Jo White Municipal Securities Issuers Neither Admit Nor Deny Settlements SEC Securities Fraud Statute of Limitations Whistleblowers

January 2014 Recent Trends and Patterns in Foreign Corrupt Practices Act (FCPA) - Enforcement report only

In this issue: - Enforcement Actions and Strategies - Perennial Statutory Issues - Unusual Developments - Compliance Guidance - Private Litigation - Enforcement in the United...more

1/7/2014 - Compliance Enforcement Enforcement Actions FCPA OECD UK Voluntary Disclosure

The DOJ’s Antitrust Division Cuts Back On Its Carve-Out Policy For Corporate Officers In Plea Agreements

Last Friday, Bill Baer, Assistant Attorney General for the Department of Justice’s Antitrust Division, announced that the Division will no longer publicly name the executives excluded from immunity granted in corporate cartel...more

4/16/2013 - Cartels Corporate Counsel Corporate Fraud Corporate Officers DOJ Immunity

Supreme Court rejects SEC’s request for exception to statute of limitations in Gabelli

On February 27, 2013, the Supreme Court issued its much-anticipated decision in Gabelli v. SEC, unanimously rejecting the SEC’s view that government agencies can bring enforcement actions seeking civil penalties for...more

3/1/2013 - Gabelli v SEC SCOTUS SEC Statute of Limitations

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