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Ten Hallmarks of an Effective Compliance Program-Hallmark 4 [Video]

In this 10-episode podcast series I take a look at all ten hallmarks of an effective compliance program as set out in the FCPA Guidance. In this episode I review Hallmark 4-risk assessments....more

Your daily dose of financial news - The Brief – 8.24.16

Apollo Global has settled its ongoing dispute with federal regulators, with the private equity firm agreeing to cough up $53 million to the SEC over an “array of [alleged] securities law violations”....more

Hallmark 4- Risk Assessments

One cannot really say enough about risk assessments in the context of anti-corruption programs. Since at least 1999 the DOJ has said that risk assessments that measure the likelihood and severity of possible Foreign Corrupt...more

Hallmark 3 – Oversight, Autonomy and Resources

I. Autonomy - The DOJ has made clear over the years the importance of this hallmark. In the FCPA Guidance it states, “In appraising a compliance program, DOJ and SEC also consider whether a company has assigned...more

ISDA Launches 2016 Variation Margin Protocol to Facilitate Compliance With Margin Rules

On August 16, 2016, the International Swaps and Derivatives Association, Inc. (ISDA) published the ISDA 2016 Variation Margin Protocol (VM Protocol). The VM Protocol will help market participants implement the new variation...more

Singapore Legal Update - July 2016

A Conditional Primary Obligation to Pay Is Not a Penalty - In iTronic Holdings Pte Ltd v Tan Swee Leon [2016] SGHC 77 (Singapore High Court, 21 April 2016), the Singapore High Court held that an obligation to pay a...more

Ten Hallmarks of an Effective Compliance Program-Hallmark 3 [Video]

In this 10-episode podcast series I take a look at all ten hallmarks of an effective compliance program as set out in the FCPA Guidance. In this episode I review Hallmark 3 - Oversight, Autonomy and Resources....more

NBU lifts pricing expertise requirements for imported services

Starting from 19 August 2016, Ukrainian residents are no longer required to obtain a pricing expertise certificate issued by the State Information and Analytical Centre for Monitoring International Commodity Markets in order...more

Financial Stability Board Reports on Risks Posed by Central Counterparties and the CCP Workplan

The Financial Stability Board published a progress report on its CCP workplan. The progress report provides an update on implementation of a workplan agreed on by the FSB, the Basel Committee on Banking Supervision, the...more

Bridging the Week - August 2016 #3

Another Publicly Traded Firm Sanctioned by SEC For Allegedly Undercutting Whistleblower Protections Through Severance Agreements: Health Net, Inc., a formerly publicly traded company whose securities were registered with the...more

Hallmark 2 – Code of Conduct and Compliance Policies and Procedures

The cornerstone of a Foreign Corrupt Practices Act (FCPA) compliance program is its written protocols. This includes a Code of Conduct, policies and procedures. In the FCPA Guidance, the Department of Justice (DOJ) and...more

ISDA Publishes Variation Margin Protocol

On August 16, 2016, the International Swaps and Derivatives Association, Inc. (ISDA) published the ISDA 2016 Variation Margin Protocol (VM Protocol). The VM Protocol is intended as a tool to help market participants that will...more

Ten Hallmarks of an Effective Compliance Program-Hallmark 2 [Video]

In this 10-episode podcast series I take a look at all ten hallmarks of an effective compliance program as set out in the FCPA Guidance. In this episode I review Hallmark 2-Code of Conduct and Compliance Policies and...more

New Regulation issued governing non-Jordanian Investment

Regulation No. 77 of 2016 governing non-Jordanian Investment (the Regulation) has been published in the Official Gazette on 16/6/2016. The Regulation offers significant changes as compared with the old regulation, which...more

Hallmark 1 – Commitment from Senior Management and a Clearly Articulated Policy Against Corruption

Over the next two weeks I will be revisiting the Ten Hallmarks of an Effective Compliance program, as laid out in the 2012 A Resource Guide to the U.S. Foreign Corrupt Practices Act ( FCPA Guidance) authored by the Criminal...more

This Week in FCPA-Episode 18, the Olympics edition [Video]

Show notes for week ending August 19, 2016: 1. Key Energy FCPA enforcement action. 2. More Och-Ziff FCPA news as its “Fixer” is arrested for FCPA violations. 3. EU’s to Olympic committee arrested and charged with ticket...more

Ten Hallmarks of an Effective Compliance Program-Hallmark 1 [Video]

In this series, I review the Ten Hallmarks of an Effective Compliance Program. This episode premiers Hallmark No. 1....more

FCPA Compliance Report-Episode 274, Scott Lane on an holistic approach to third party management [Video]

In this episode, I visit with Red Flag Group CEO Scott Lane on a holistic approach to third part risk management....more

FCPA Compliance Report-Episode 273 [Video]

In this episode, I visit with Marc Bohn, Counsel at Miller & Chevalier on the recent 11th circuit opinion limiting the SOL on profit disgorgement claims to 5 years and the IRS tax letter holding payments for profit...more

After Adopting the “Fraud-on-the-Market” Presumption of Reliance, Australia is Poised to Become a Plaintiff-Friendly Venue

The United States is a popular location for securities class actions, due in large part to its reputation as a generally plaintiff-friendly system. A key contributor to that reputation is the acceptance of the...more

Your daily dose of financial news - The Brief – 8.19.16

The Journal reports that big companies [banks included] are pouring more into dividends than at “any time since the financial crisis”—likely, a response to record-low bond yields that’s “put a premium” on kicking back...more

China Gives Green Light to the Launch of Shenzhen-Hong Kong Stock Connect

According to the joint announcement of the China Securities Regulatory Commission ("CSRC") and the Securities and Futures Commission of Hong Kong ("SFC") dated 16 August 2016, the two regulatory authorities have approved, in...more

This Week In Securities Litigation

An investment banker who repeatedly tipped his father on about pending mergers was found guilty of insider trading by a jury this week. The Commission brought another action based on the whistleblower protections where the...more

Compliance is a Business

Compliance is a business. That statement should not come as a shock or even a surprise to anyone who has worked in the corporate world. Every part of a business should work towards doing business. Yet many compliance...more

EPA and NHTA Finalize Stringent Emission and Fuel Efficiency Standards

Yesterday, the U.S. Environmental Protection Agency (EPA) and the National Highway Traffic Safety Administration (NHTSA) finalized more stringent greenhouse gas (GHG) emission standards and fuel efficiency standards for...more

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