Fine Tuning Your Anti Corruption Compliance Program
Creating an Integrated Due Diligence System - Screening to Audits
A Moment of Simple Justice - Revenge Porn
Third Party Due Diligence When is Enough, Enough?
An FCPA Review: A Look Back at 2013 and Trends for 2014
Anti Kickback and Stark Law Enforcement and Compliance Issues
Conducting Interviews in an Internal Investigation 2 13 14, 9 03 AM
A Moment of Simple Justice: Legal Weed
Building an Anti Corruption Compliance Program Practical Steps 2 18 14, 9 02 AM
Internal Investigations: Soup to Nuts (March 13, 2014)
How Can You Better Protect Yourself with the Escalating Trend of FCPA Enforcement?
The Role of a Chief Compliance Officer: Navigating the Compliance Landscape (March 18, 2014)
Keeping Your Due Diligence System Manageable March 31, 2014
Tailoring Your Anti Corruption Program to a Risk Assessment
Managing Your Anti Corruption Policies and Procedures
Designing Cost Effective Risk Assessment Programs May 21, 2014
Managing Your Internal Investigation Program June 3 2014
AML BSA and Sanctions Compliance Part II of II June 24, 2014
AML BSA and Sanctions Compliance I of II June 10 2014
Are Criminal Laws the Right Response to Revenge Porn?
On December 13, the FSA published a press release announcing that Thomas Ammann, a former investment banker and FSA Approved Person at Mizuho International plc, had been sentenced to 2 years and 8 months imprisonment for two...more
The Department of Justice and Securities Exchange Commission loudly have trumpeted victories achieved in their renewed battle against insider trading and Wall Street malfeasance, repeatedly warning that there are more cases...more
John Hanson, a former FBI Agent and practicing forensic accountant, takes you inside of his mind and behind the numbers of a Ponzi Scheme to answer the universal question: "Where did all that money go?"
Based on actual...more
In This Issue:
- "Second Circuit Clarifies “Substantial Assistance” Standard for Aiding and Abetting Liability in SEC Enforcement Actions"
- "NLRB Prohibits Employers from Requesting that Employees Keep Silent...more
On September 4, 2012, the Financial Services Agency of Japan (“FSA”) published its proposal of measures to prevent the recurrence of the AIJ scandal while providing the opportunity to the public to provide their opinions...more
On August 22, the U.S. District Court for the Middle District of Florida denied a major bank’s motion to enjoin prosecution by two state attorneys general of claims related to the bank’s credit card payment protection...more
On July 3, HM Treasury published a consultation paper on sanctions for the directors of failed banks.
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
Last month, in a potentially significant but largely overlooked development, the Department of Justice ("DOJ") signaled that it would "increasingly" pursue "innovative, non-monetary measures" when it settles civil fraud...more
On July 2, the FSA published a speech by Tracey McDermott, acting director of the FSA’s Enforcement and Financial Crime Division. The speech focused on credible deterrence and the approach that the Financial Conduct Authority...more
On 12 June 2012, the Presidency of the Council of the EU published a new compromise proposal (dated 11 June 2012) on the proposed Regulation on insider dealing and market manipulation (MAR).
Originally published in Law360, New York on June 13, 2012.
Government contractors know to train their employees, agents and subcontractors to comply with the myriad laws and regulations governing their business...more
On 28 May 2012, the FSA announced that three defendants with links to Blue Index Ltd, a contract for difference brokerage, pleaded guilty to charges of insider dealing. These are James Sanders, a director of Blue Index,...more
Responding to a requirement in the Dodd-Frank Act that it review, and if appropriate, amend, the federal sentencing guidelines for mortgage fraud, the U.S. Sentencing Commission set forth on April 13, 2012, two new provisions...more
On May 2, DOJ and HHS announced charges against 107 individuals, including doctors, nurses and other licensed medical professionals, across the country for allegedly participating in Medicare fraud schemes totaling $452...more
Mintz Levin’s Health Care Fraud Enforcement Defense group has published a series of “Year in Review” articles discussing its observations about health care fraud enforcement trends in 2011 and its opinions...more
2012 is already a record-breaking year in health care fraud enforcement. This week Attorney General Eric Holder and Secretary of the Department of Health and Human Services (HHS) Kathleen Sebelius announced the biggest...more
Taking it from the top:
- Last Friday, the SEC sued two twin brothers from the U.K. with creating and promoting a fake “stock picking robot” that purportedly identified penny stocks set to double in price. “Instead, the...more
A hearing titled Anatomy of a Fraud Bust: From Investigation to Conviction held by the Senate Committee on Finance (Committee) on April 24th allowed federal health care agencies to both tout their fraud-fighting successes,...more
Science Applications International Corp (SAIC) has agreed to pay more than $500 million in fines and penalties to settle federal charges alleging that the outsourcing company overcharged the city of New York for work and...more
I’d like to try a weekly post with short bits recapping what I think are the most interesting stories or cases from the past week. We’ll see how it works, but for this week:
- Matt Solomon, an AUSA in the District of...more
In This Presentation:
- FSA Enforcement 2012
- Novel Approaches
- Market Abuse- Insider dealing
- Inside Information
- No Penalty – s123(2) FSMA
- Background - Punch Taverns...more
Over the years, I’ve noted that a number of evil twins have walked the corporate securities law stage.
Other People’s Money
O.P.M. Leasing Services, Inc. was a large computer leasing company that crashed into...more
The longest prison term ever imposed in a Foreign Corrupt Practices Act (“FCPA”) case -- fifteen years -- was recently given to Joel Esquenazi, former president of Terra Telecommunications Corporation, after a jury convicted...more
British pharmaceutical company GlaxoSmithKline (GSK) announced on November 3, 2011, that it had reached an agreement in principle with the United States government to resolve multiple federal investigations regarding the...more
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