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Porter Hedges LLP

ComEd Settlement Proves the Foreign Corrupt Practices Act Is Not Limited to Foreign Corruption

Porter Hedges LLP on

On September 28, 2023, the Securities and Exchange Commission (“SEC”) announced that it reached a settlement with Exelon Corporation and its subsidiary, Commonwealth Edison Company (“ComEd”), relating to charges that ComEd...more

Burr & Forman

FINRA Vendor-Management Guidance: You Can’t Outsource Responsibility

Burr & Forman on

On August 13, 2021, the Financial Industry Regulatory Authority (“FINRA”) issued Regulatory Notice 21-29, collecting guidance on outsourcing and vendor management.  The Notice was prompted by increased reliance on outsourcing...more

Thomas Fox - Compliance Evangelist

The Dutch Tulip Bubble and Internal Controls for Third Parties

Internal controls are a key tool to operationalize your third-party risk management program. The basic internal controls, that should be a part of any financial controls system. There were four significant controls the...more

Thomas Fox - Compliance Evangelist

Enforcement Week III: Johnson Controls FCPA Enforcement Action – Part 2

I continue my review of the Johnson Controls, Inc. (JCI) Foreign Corrupt Practices Act (FCPA) enforcement action today by focusing on the Department of Justice’s (DOJ’s) Declination to Prosecute. Yesterday, I considered the...more

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