FCPA: Recent Enforcement Activity Sounds Warning for Financial Services Industry

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"When Cheryl J. Scarboro, Chief of the U.S. Securities and Exchange Comission's (SEC) Foreign Corrupt Practices Act (FCPA) enforcement unit, remarked in November 2010 that her unit "will continue to focus on industry-wide sweeps and [that] no industry is immune from [FCPA] investigation," the financial services industry would have been wise to take notice. Now, with news that the SEC is examining whether banks and private equity firms have run afoul of the FCPA in their dealings with sovereign wealth funds (SWFs), Scarboro's remarks are no longer merely a harbinger for FCPA enforcement activity - they represent the reality facing the financial services industry."

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Published In: Criminal Law Updates, Finance & Banking Updates, Securities Updates

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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