5 Key Takeaways | 2024 Emerging Trends: Delaware Unclaimed Property VDA and Multistate Audits
Common Scenarios Triggering False Claims Act Violations, Part 3: Claims and Investigations
Compliance Tip of the Day: Machine Learning for Internal Audit
DE Under 3: OFCCP Changes Up Important Technical Details of its Audit Selection Process in First FY 2024 CSAL
Preparing for a Government Healthcare Audit
What Can A Tax Attorney Do For You? A Podcast With Janathan Allen
Navigating GSA Audits Compliance Strategies and Best Practices
DE Under 3: US DOL Inspector General’s Office Plans to Review Effectiveness of OFCCP Compliance Evaluations
DE Under 3: What Federal Contractors Need to Know About OFCCP's New Audit Scheduling Letter
DE Under 3: What’s New in OFCCP’s Latest Audit Scheduling Letter for Supply & Service Contractors
Independent Audits of Nonprofit Organizations With Douglas Cook
DE Under 3: U.S. OPM Proposed Allowing Federal Managers To Avoid Most Qualified Candidates To Pick Those Who Offer Better “Fit”
AGG Talks: Home Health & Hospice - Reimbursement Audits and Appeals
After ALJ: Options and Opportunities in the Face of an Unfavorable ALJ Decision
The Presumption of Innocence Podcast: Episode 21 - Conservation Easement Donations: Tax Shelter or Charitable Contribution Deduction?
Compliance and Managing from the Middle
I Understood There Would Be No Math: Audits, Extrapolations, and a New Set of Rules
JONES DAY PRESENTS®: Trade Secret Audits: Enhanced Mapping, Protecting Access and Creating Understanding
Constangy Webinar - DEI Audits: Tools to Enhance Your DEI Practices
[Podcast] New Year, New PAC: Have a Successful PAC Audit in 2023
On November 14, 2023 the Securities and Exchange Commission (SEC) released its annual Office of the Whistleblower Report to Congress for fiscal year 2023 (October 1, 2022-September 30, 2023). This report highlighted several...more
The following newsletter provides a roundup summarizing enforcement actions, guidance, rulemakings, and other public statements taken by a federal and/or state financial services regulatory agency, specifically focusing on:...more
On the heels of record-breaking enforcement in 2022, expect continued aggressive pursuit of Chair Gensler’s priorities in 2023. The SEC will continue to bring its considerable resources to bear to address ESG-related...more
Two Years Later, Regulation BI Remains a “Tremendous Priority” for FINRA - June 30th marked two years since the implementation of Regulation Best Interest (“Reg BI”) and the client relationship summary or Form CRS. Firm...more
The Nutter Securities Enforcement Update is a periodic summary of noteworthy recent securities enforcement activity, settlements, decisions, and charges. ...more
On July 13, 2021, the SEC announced charges against Stable Road Acquisition Company (“Stable Road”), its sponsor, SRC-NI, its CEO, Brian Kabot, Stable Road’s proposed merger target Momentus Inc.(“Momentus”), and Momentus’s...more
While gearing up to get trillions of dollars into the economy, the government was also setting in place the mechanism to investigate and prosecute fraud related to these programs. The CARES Act was signed into law on March...more
On May 2, 2019, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued guidance titled “A Framework for OFAC Compliance Commitments” (Guidance), providing direction regarding what OFAC considers to...more
The Commission resolved its actions against the PRC based affiliates of five major accounting firms for failure to produce audit work papers. The settlement contains a series of procedures designed to facilitate production in...more
In recent years, the Securities and Exchange Commission (SEC) and Financial Industry Regulatory Authority (FINRA) have heightened their expectations of what constitutes a “comprehensive” branch self-inspection program. Firms...more
The SEC brought a settled administrative action against an auditor on October 24th. Often I’ll take a case like this and write something about it to warn other auditors (or investment advisers or broker-dealers, or whomever)...more
The SEC announced charges against an investment advisory firm and three of its top officials for violating the “custody rule” that requires firms to follow certain procedures when they control or have access to client money...more
Issuers, underwriters and advisors in the municipal bond marketplace are facing unprecedented challenges from federal regulators in connection with both the issuance of bonds and ongoing post-issuance compliance. These...more
The Commission prevailed on summary judgment in an action against a broker which alleged he misappropriated client funds. The agency also filed actions centered on: an audit failure; the EB-5 immigration program; undisclosed...more
The unblemished record of the Manhattan U.S. Attorney’s Office in insider trading cases came to an end this week with the acquittal of Rengan Rajaratnam, brother of the convicted Galleon Fund founder. This is the first loss...more
In a holiday shortened week, dark pools were again a focus for regulators. This week FINRA sanctioned Goldman Sachs in connection with the operation of its dark pool....more
The PCAOB’s new and amended auditing standards, adopted on June 10 and subject to SEC approval, require that auditors, among other things, discuss related party transactions and executive officers’ financial arrangements with...more
In This Issue: Introduction; Redesigning the SEC’s Division of Enforcement, Again; Focus Areas: What’s Next; Overview of 2013 Cases; Public Company, Officer, and Director Trends; Audit Firm and Auditor Trends; Rule...more
The Commission, as part of its retooled enforcement program, is, in part, focusing on gatekeepers such as attorneys and accounts in an effort to achieve omnipresence. This has resulted in a number of proceedings against...more
- Regulatory Updates: CFTC Adopts “Substituted Compliance” Approach for Registered Investment Companies that are Commodity Pools; SEC’s Final Rules on General Solicitation and Bad Actor Disqualification for Investment...more
FINRA recently amended Rule 4530 (Reporting Requirements) to make required reporting by member firms of certain regulatory and disciplinary events less burdensome. Those relatively minor changes will be discussed below. But...more
This Part III is the final installment of my review of the Eli Lilly and Company (Lilly) FCPA enforcement action brought by the Securities and Exchange Commission (SEC). In this Part III, I will review the FCPA issues that...more