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Top Ten International Anti-Corruption Developments for May 2016

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 from the past month, with links to primary...more

This Week In Securities Litigation

Merrill Lynch was at the center of actions brought by the SEC and FINRA this week. One action charged the firm with violations of the customer protection rule tied to using customer cash and failing to protect their...more

This Week In Securities Litigation

Insider trading was a key focus this week. Two actions were brought based on information secured from the FDA and CMS by former employees who were employed by and investment adviser. Another case centered on tips by a...more

This Week In Securities Litigation

The elements of an insider trading claim continued to be a key focus this week. The first circuit, following prior circuit precedent, held that a personal benefit based on a long term friendship and a steak dinner was...more

DOJ Announces First Declinations After Implementing FCPA Pilot Program

The U.S. Department of Justice (DOJ) issued its first set of public declinations since its April unveiling of a new self-reporting Foreign Corrupt Practices Act (FCPA) pilot program. On June 7, 2016, Akamai Technologies,...more

DOJ Declines Prosecution in Two FCPA Cases, SEC Executes NPAs

The DOJ declined prosecution in two self-reported potential FCPA actions while the SEC entered into non-prosecution agreements with each issuer. One matter involved Akamai Technologies, Inc. while the other centered on...more

Want to Work in Compliance – Learn How to Read a Balance Sheet

One of the most interesting tag lines I heard at Compliance Week 2016 was the following, if you want to work in my compliance department; you need to learn how to read a balance sheet. I thought that single line encapsulated...more

ISO 37001: A New Measuring Stick for Corporate Compliance Programs

The International Organization for Standardization is developing a certifiable international standard for “anti-bribery management systems” that could influence how the US Department of Justice, US Securities and Exchange...more

DOJ’s New FCPA “Pilot Program” Targets Corporate Officers and Other Individuals

For years, FCPA observers have predicted that the Department of Justice (“DOJ”) will increase its prosecutions of corporate officers and employees for FCPA violations. These predictions have so far proven disputable, as the...more

Dorsey Anti-Corruption Digest - April 2016

Welcome to Dorsey & Whitney’s monthly Anti-Corruption Digest. In this digest, we draw together news of enforcement activity throughout the world and aim to reduce your information overload. Our London, Minneapolis, New York...more

DOJ Launches FCPA Pilot Program to Promote Company Self-Reporting

In a speech delivered last Wednesday by Assistant Attorney General Leslie Caldwell, the Justice Department’s (“DOJ”) Criminal Division announced the launch of a new Foreign Corrupt Practices Act (“FCPA”) “pilot program” that...more

DOJ’s Fraud Section Issues Foreign Corrupt Practices Act Enforcement Plan and Guidance

On April 5, 2016, the Department of Justice’s Fraud Section (“DOJ”) issued its Foreign Corrupt Practices Act (“FCPA”) Enforcement Plan and Guidance (“Guidance”), which announced (1) a more than doubling of DOJ resources...more

Bridging the Week - March 2016 #4

Alleged Spoofer, Blamed for Partly Causing Flash Crash, Loses UK Extradition Hearing - Navinder Sarao, the London-based futures trader who in April 2015 was sued by the Commodity Futures Trading Commission and criminally...more

Bridging the Week - March 2016 #2

Federal Court Allows Former Hedge Fund Operator’s Lawsuit Alleging Civil Rights Violations to Proceed Against US Attorney and Other Government Officials: A federal court in New York City refused to dismiss a lawsuit against...more

SEC Describes Recent Efforts to Combat Pyramid Schemes and Affinity Frauds

Over the past two years, the Securities and Exchange Commission (SEC) has stepped up enforcement actions against pyramid schemes and related affinity frauds. Last week, in a speech at the University of Illinois at Chicago,...more

VimpelCom's Global FCPA Settlement - A Multinational Resolution

The U.S. Department of Justice (DOJ), the U.S. Securities and Exchange Commission (SEC) and the Public Prosecution Service of the Netherlands (OM) announced a coordinated criminal and civil Foreign Corrupt Practices Act...more

Key Takeaways From This Year’s Early FCPA Enforcement Actions

February has been a big month for U.S. Foreign Corrupt Practices Act (FCPA) enforcement. It started with the U.S. Securities and Exchange Commission (SEC) quietly resolving a string of relatively small matters. Then, at the...more

SEC Announces Its First Deferred Prosecution Agreement With an Individual in an FCPA Case

On February 16, 2016, the SEC announced its first ever deferred prosecution agreement (“DPA”) with an individual in a Foreign Corrupt Practices Act (“FCPA”) case. As part of a settlement in which a Massachusetts-based...more

PTC Inc. Reaches $28M Settlement with DOJ and SEC to Resolve China FCPA Allegations

On February 16, 2016, two Chinese subsidiaries of Massachusetts-based software company PTC Inc. (“PTC”) entered into a non-prosecution agreement with the U.S. Department of Justice (“DOJ”) and will pay $14.54 million to...more

Travel, Entertainment, Gifts Yield DOJ, SEC FCPA Charges Again

Travel, entertainment and gifts tied to inadequate controls are recurrent themes in FCPA cases. Many of these cases involve the use of agents and center in China. Each of these recurrent items appear in the most recent FCPA...more

CFTC Alert: 2015 CFTC Year-in-Review, and a Look Forward

CFTC continues to bring high-profile, large-penalty enforcement cases; begins bringing cases to enforce Dodd-Frank Act implementing regulations; and embarks on post-Dodd-Frank Act regulatory initiatives. Please see...more

The Supreme Court

The Supreme Court of the United States issued decisions in four cases today: Campbell-Ewald v. Gomez, No. 14-857: Respondent Jose Gomez received Navy recruitment text messages without his consent. He filed a nationwide...more

Foreign Corrupt Practices Act Enforcement 2016: In Like A Lamb, Out Like A Lion

In 2015, the U.S. Government significantly bolstered its resources dedicated to combat international corporate bribery under the Foreign Corrupt Practices Act ("FCPA"). By announcing the addition of a team of FCPA-dedicated...more

U.S. and China Sign Financial Intelligence Cooperation Memorandum

The U.S. Financial Crimes Enforcement Network (FinCEN) and the China Anti-Money Laundering Monitoring and Analysis Center (CAMLMAC) recently signed a Memorandum of Understanding (MOU) to create a “framework to facilitate...more

Your daily dose of financial news The Brief – 12.18.15

As expected based on earlier rumors, Avon has struck a deal with Cerberus Capital Management to split off its North American business. Cerberus will acquire an 80.1% stake in Avon North America and also kick in a $435 million...more

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