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Compliance Barclays

Compliance programs typically refer to formalized institutional procedures within corporations and organizations to detect, prevent and respond to indvidual and widespread instances of regulatory violations. ... more +
Compliance programs typically refer to formalized institutional procedures within corporations and organizations to detect, prevent and respond to indvidual and widespread instances of regulatory violations.  In response to many corporate scandals evidencing rampant unethical business practices, many nations, including the United States, began passing strict regulatory frameworks aimed at curbing these abuses. Notable pieces of legislation in this area include the U.S. Foreign Corrupt Practices Act (FCPA), Sarbanes-Oxley (SOX), and the U.K. Bribery Act, to name a few. The foregoing statutes and the severe penalties often associated with them form the basis of many modern institutional compliance programs. less -
Thomas Fox - Compliance Evangelist

Top SEC Enforcement Actions from 2019

Yesterday, I considered five Department of Justice (DOJ) Foreign Corrupt Practices Act (FCPA) enforcement actions. Today, I want to look at key FCPA enforcement actions by the Securities and Exchange Commission (SEC)....more

Thomas Fox - Compliance Evangelist

Barclays – Back to the Basics

This week I am considering the recent spate of Foreign Corrupt Practices Act (FCPA) enforcement actions brought by the Securities and Exchange Commission (SEC) at the close of its fiscal year. Last week saw several...more

The Volkov Law Group

Barclays Agrees to Pay the SEC $6.3 Million to Settle FCPA Offenses for Hiring of Relatives of Foreign Officials in Asia

The Volkov Law Group on

Barclays joined the club of global financial institutions settling FCPA violations for hiring of relatives of foreign officials in Asia.  Barclays agreed to disgorge $3.8 million and paid prejudgment interest of nearly $1...more

Thomas Fox - Compliance Evangelist

Year End (FCPA) Closeouts: Quad/Graphics, Barclays and Westport Fuel Systems

The US government fiscal year ends today. Just as in the business world, where many companies try and clear out any unexecuted deals or open contracts, we saw the Securities and Exchange Commission (SEC) clear out three...more

The Volkov Law Group

Antitrust Division Continues to Wrestle with Credit for Pre-Enforcement Compliance Programs

The Volkov Law Group on

The Justice Department’s Antitrust Division maintains a robust criminal enforcement program fueled by the steady stream of leniency applicants. Since the 1990s, the Antitrust Division has trumpeted a successful leniency...more

Thomas Fox - Compliance Evangelist

Farewell to Sam Shepard: Wither Whistleblowers in the UK?

American’s greatest living playwright died yesterday as Sam Shepard passed away from Lou Gehrig’s disease. According to his obituary in the New York Times (NYT) “In Mr. Shepard’s plays, the only undeniable truth is that of...more

Thomas Fox - Compliance Evangelist

This Week in FCPA-Episode 58, the Declination Edition

After last week’s guest announcers, Jay and I return for a wide-ranging discussion on some of the week’s top compliance related stories, including: 1. The first Declination of the Session’s Justice Department, Linde gas. ...more

Thomas Fox - Compliance Evangelist

Sgt. Peppers at 50: She’s Leaving Home and Barclays Bank

It has unquestionably been a difficult year for Barclays. Whether any of its former executives will face any jail time for their actions back in the 2008 financial crisis is an open question. As for current bank chief Staley,...more

The Volkov Law Group

The Often Ignored Importance of Antitrust Compliance (Part I of II)

The Volkov Law Group on

If you ask any Chief Compliance Officer whether their compliance program includes antitrust laws, they will respond quickly and tell you – “Of course we do.” If you follow up you initial question and ask how do you ensure...more

Cadwalader, Wickersham & Taft LLP

Initial Decision Finds that BP Manipulated 2008 Natural Gas Market in Texas

On August 13, 2015, a Federal Energy Regulatory Commission (“FERC” or “Commission”) Administrative Law Judge (“ALJ”) issued an initial decision in which she found that BP America Inc. et al. (“BP”) manipulated the natural...more

Thomas Fox - Compliance Evangelist

Hemingway and Trust and Respect for Compliance Leadership

On this day in 1899, Ernest Hemingway was born. To me, he was the greatest Man of Letters the US has produced. Probably like most of you all, I was introduced to Hemingway in high school through The Son Also Rises. It remains...more

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