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Survey: 28 Reasons Why The Typical Compliance Officer’s Week Leaves Dangerously Little Time for Corporate Ethics Training

I just downloaded and read the annual Cost of Compliance survey compiled by Thomson Reuters Accelus. It’s very interesting reading for those of us in the ethics and compliance industry. In my last blog post about the ERC...more

Red Notice Newsletter - March 2014

This month on the anticorruption front, a New York court orders two former Siemens executives to pay record civil penalties in a bribery case involving the company’s Argentina business; Canada prosecutes former executives...more

C’Mon Man Or The End Of The World?

It’s the end of the world as we know it,It’s the end of the world as we know it,It’s the end of the world as we know it, and I feel fine - The above lyrics came from REM and they reflect how I generally feel about law...more

Second Circuit Reverses Convictions In Municipal Bonds Cartel Case

Court’s application of statute of limitations will likely guide future conspiracy prosecutions. On December 9, 2013, the Second Circuit Court of Appeals issued a 2-1 opinion reversing the conviction of three...more

How to Conduct Routine Internal Investigations [Video]

The art of day-to-day internal investigations has been ignored in favor of media reports on high-profile, high-stakes internal investigations. With the increasing threat of whistleblower complaints and increasing...more

February 2013: Libor Litigation Update

UBS and Barclays Acknowledge Making False Libor Submissions. Investigations into misconduct at UBS and Barclays have revealed pervasive corruption of the London Interbank Offered Rate (“Libor”), which provides a benchmark for...more

Ticking Time Bomb: Private LIBOR Litigation

One by one global banks are being ensnared in the LIBOR prosecution net. Late last year UBS, the Swiss banking giant, entered into a massive settlement in which it agreed to pay approximately $1.5 billion in fines and...more

Criminal Antitrust Update - January 2013

In This Issue: - INDUSTRY SCORECARD - Technology: An executive of AU Optronics Corp. (“AUO”) was convicted of price-fixing in the LCD flat screen markets in a re-trial. Steven Leung was involved in the sale of...more

Banks Take It On The Chin

The end of the year was very tough for global banks. For months significant enforcement actions were expected in the ongoing LIBOR manipulation probe and anti-money laundering and sanctions violations probes....more

2012 DOJ Criminal Antitrust Results Show Increased Risk For International Businesses And Employees

The holidays have come early for the Department of Justice’s Antitrust Division. The new fiscal year 2012 statistics for the Division’s accomplishments have been released. The statistics reveal that the Division’s criminal...more

Resource Guide to the U.S. Foreign Corrupt Practices Act (FCPA)

The definitive guide to complying with the Foreign Corrupt Practices Act, written by those in charge of enforcing it: The Securities and Exchange Commission and the Department of Justice. From the SEC website: "The guide...more

Criminal Antitrust Update - October 2012

In this issue: - INDUSTRY SCORECARD - E-books: Following its settlement with the U.S. Justice Department’s Antitrust Division (the “Division”) regarding price-fixing allegations related to electronic book sales,...more

Practical Law Multi-Jurisdictional Guide 2012/13: Corporate Crime, Fraud and Investigations: Japan

Originally published in Corporate Crime, Fraud and Investigations multi-jurisdictional guide 2012/13 and is reproduced with the permission of the publisher, Practical Law Company. - FRAUD - Regulatory provisions and...more

The LIBOR Scandal Unraveled

The LIBOR “scandal” could have far-reaching implications for financial institutions in the United States and global markets. It is hard to know exactly how the issue will play out. The Department of Justice is definitely...more

Criminal Antitrust Update - July 2012

In This Issue: - INDUSTRY SCORECARD - CASE NOTE: FINANCIAL DAMAGES MUST BE DECIDED BY JURIES - SEVENTH CIRCUIT TAKES BROAD VIEW OF THE FTAIA ...more

SFO Press Release on Manipulation of LIBOR

On July 2, the Serious Fraud Office (SFO) published a press release regarding the manipulation of the setting of the London Interbank Offered Rate (LIBOR). In the press release, the SFO stated that it had been working...more

OFAC’s Long Arm of the Law

Who would have ever guessed that the largest corporate penalty paid in 2012 would be an OFAC enforcement action. The Justice Department has many major FCPA enforcement actions in the queue awaiting approval and public...more

Criminal Antitrust Update - June 2012

In This Issue: - INDUSTRY SCORECARD - Credit Card Fees: Since it suffered an adverse ruling from the European Commission in 2007, MasterCard has been trying to overturn a ruling that prohibited the company from...more

Morgan Stanley Goes One for One with a Best Practices Compliance Program

I believe that the Peterson enforcement action is one of the most significant in 2012 to date. It provides solid guidance to the compliance practitioner on what the DOJ and SEC think is important and gives you actions that...more

The Impact of the New York Times Report on Wal-Mart’s Bribery Scandal

The New York Times report on Wal-Mart’s handling of bribery allegation has shaken the anti-corruption community. The New York Times’ description of what occurred inside of Wal-Mart, if true, is devastating. Here is a link...more

Criminal Antitrust Update - April 2012

In This Issue: - Industry Scorecard - Case Development – Supreme Court Declines to Hear Foreign Trade Antitrust Improvements Act Appeal - The Impact of the AU Optronics Corp. Convictions Excerpt from Industry...more

Aggressive FCPA Enforcement Persists: Increased Activity, Along With Recent Legal Developments, Mandate that Companies Remain...

Enforcement of the U.S. Foreign Corrupt Practices Act continues to increase dramatically. The U.S. government is dedicating more resources to FCPA enforcement and bringing more enforcement actions than ever before. This...more

ANTI-CORRUPTION COMPLIANCE: DRILLING DOWN ON DOCUMENTATION

A key, but often overlooked, part of any anti-corruption compliance program is the need to document decisions made by the company. Documentation is critical to demonstrate the company's intent -- the absence of criminal...more

From Whistleblower to RICO Claimant

The holiday season is past and many of us have returned to work. However, if you are a Chief Compliance Officer (CCO) there is a gift that you may wish to give yourself, it is “The Whistleblower’s Handbook - A Step-by-Step...more

The lawyer's smoking gun: insolvency, fraud and privilege

Directors may rely on the company lawyer's confidential advice, only to find it released to prosecutors or regulators by a liquidator. Is that allowed? read on...more

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