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 you can engage in now to increase the visibility of your compliance program within your company. Kudos to Morgan Stanley for their compliance victory. You do not have to parade in five pitchers to pitch to five different batters as Brad Mills did, but I think the import should be to take action now.
Please see full publication below for more information.