Randall Fons

Randall Fons

Morrison & Foerster LLP

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Latest Publications


Investment Management Legal + Regulatory Update - July 2015

The 2016 compliance dates for new rules included in the SEC’s money market fund reforms are fast approaching. Among other things, the reforms include changes to stress-testing requirements, disclosure requirements, net asset...more

7/29/2015 - Disclosure Requirements Liquidity Money Market Funds NAV Regulatory Agenda SEC Stress Tests

Top Ten International Anti-Corruption Developments for May 2015

In order to provide an overview for busy in-house counsel and compliance professionals, we summarize below some of the most important international anti-corruption developments in the past month with links to primary...more

6/10/2015 - Anti-Corruption Bribery Chief Compliance Officers Compliance Corruption Enforcement Enforcement Actions FCPA FIFA Kickbacks Popular

Administrative Proceedings vs. Federal Court: The SEC Provides Limited Transparency Into Its Choice of Forum

For the past two years, the SEC has come under heavy fire, both inside and outside the Commission, for its increasing use of its own administrative proceedings, rather than federal courts, as the preferred forum for bringing...more

5/13/2015 - Administrative Hearings Dodd-Frank Enforcement Actions Federal Rules of Civil Procedure Forum Selection Clause SEC

SEC Annual Conference Highlights 2014 Accomplishments and Promises to Turn Up the Heat in 2015

With Chair Mary Jo White in her second year at the helm, the Securities and Exchange Commission showcased its efforts, improvements, and enforcement successes at this year’s SEC Speaks Conference. The Commission highlighted...more

3/11/2015 - Broker-Dealer Enforcement Actions FCPA Financial Reporting Fraud Insider Trading Mary Jo White SEC

With No Civil Penalty, Goodyear FCPA Settlement Highlights Benefits of Cooperation and Remedial Actions

The Securities & Exchange Commission (“SEC”) announced last week that it charged The Goodyear Tire & Rubber Company (“Goodyear”) with violating the Foreign Corrupt Practices Act (“FCPA”), and that Goodyear agreed to pay more...more

3/10/2015 - Books & Records Bribery Enforcement Actions FCPA Foreign Subsidiaries Goodyear Popular Remedial Actions SEC Self-Reporting Settlement

A New SEC Enforcement Direction for 2014

Each year, the SEC puts on its most informative conference of the year: The SEC Speaks. During the course of the two-day conference, held this year on February 21 and 22, the Chair and each Commissioner, as well as the most...more

3/27/2014 - Enforcement SEC

Financial Reporting & Accounting Enforcement Annual Review - 2013

In This Issue: Introduction; Redesigning the SEC’s Division of Enforcement, Again; Focus Areas: What’s Next; Overview of 2013 Cases; Public Company, Officer, and Director Trends; Audit Firm and Auditor Trends; Rule...more

1/29/2014 - Audits Compliance Corporate Counsel Corporate Governance Enforcement Enforcement Actions PCAOB SEC

What’s Old is New Again: Total Settles FCPA Charges Involving Decade-Old Conduct

This week the Securities and Exchange Commission (SEC) and the Department of Justice (DOJ) announced that France-based oil and gas company Total S.A. resolved Foreign Corrupt Practices Act (FCPA) charges by agreeing to pay a...more

6/3/2013 - Bribery Compliance DOJ FCPA Penalties SEC Settlement Total SA

The SEC Speaks: Reflections and Enforcement Initiatives in 2013

Each year at The SEC Speaks, the Commissioners and senior leadership of the Securities and Exchange Commission identify the agency’s priorities and initiatives for the coming year. Of course, one of the most anticipated...more

3/6/2013 - Asset Management Disclosure Requirements FCPA Fraud Insider Trading SEC Whistleblowers

Supreme Court: Statute of Limitations in SEC Fraud Cases Begins to Run When Fraud Occurs, not When Discovered

The Supreme Court today ruled that in an SEC action to recover civil penalties, the five-year statute of limitations begins to run when fraud occurs, not when it is discovered. The Court held in Gabelli et al. v. Securities...more

2/28/2013 - Discovery Rule Gabelli v SEC SCOTUS SEC Securities Fraud Statute of Limitations

Insider Trading Annual Review - 2012

In This Issue: Overview Of Insider Trading Law; 2012 Enforcement activity; Galleon Update; Expert Network Cases; What Does Cooperation Buy You?; Global Trading, Global Enforcement; Legislative Reform; 10b5-1 Plans: Not...more

1/18/2013 - 10b5-1 Plans China Enforcement EU Federal Sentencing Guidelines Global Dealmaking Insider Trading Penalties SEC Sentencing STOCK Act

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