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Books & Records Due Diligence Compliance

BCLP

Supervision of Vendors When Outsourcing - The Buck Stops with FINRA Member Firms

BCLP on

Key Takeaways: ..On August 13, 2021, FINRA issued Regulatory Notice 21-29 (“RN 21-29”) to remind member firms that they must establish and maintain an adequate supervisory system, including written supervisory procedures...more

The Volkov Law Group

Mondelez FCPA Enforcement Action — An Abuse of Prosecutorial Discretion?

The Volkov Law Group on

The first FCPA enforcement action for 2017 landed with very little fanfare. The SEC reached a settlement with Mondelez International for $13 million. The facts surround the hiring of an agent in India and the failure of...more

Thomas Fox - Compliance Evangelist

A Company Must Do Compliance – The Mondelez FCPA Enforcement Action

In almost every Foreign Corrupt Practices Act (FCPA) enforcement action, there are nuggets to be gleaned for any Chief Compliance Officer (CCO) or compliance practitioner. All one has to do is look for them. Back in 2012,...more

The Volkov Law Group

Five Key Takeaways from Key Energy’s SEC FCPA Settlement

The Volkov Law Group on

The SEC, last week, announced its $5 million settlement with Key Energy. As always, FCPA settlements contain important examples of enforcement priorities and policies. Key Energy’s recent settlement is an example of the...more

McDermott Will & Emery

Inside M&A - Winter 2013

McDermott Will & Emery on

In This Issue: - FCPA Due Diligence is Critical to Avoid Successor Liability in Cross-Border Transactions - China’s Merger Control Rules...more

Thomas Fox - Compliance Evangelist

The HP Acquisition of Autonomy – Lessons Learned for Doing Compliance ‘By the Book’

Doing something ‘by the book’ means more than following a process. It means following that process during high stress times. One of the things that I think gets missed when discussing compliance programs is the need for rigor...more

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