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News & Analysis as of

The FIFA Indictments and Travel Act Prosecutions under the FCPA

While the indictments last week against 14 individuals who were members or associated with Fédération Internationale de Football Association (FIFA) did not include any alleged violations of the Foreign Corrupt Practices Act...more

Recent Latin-American Anti-Corruption Investigations and Cases

In the last few years, several Latin American countries and the United States have increased their focus on anti-corruption matters. This article will survey some of the most significant recent public anti-corruption...more

No More He-Said-She-Said: Revised Regulations Allow CMS to Request Records Information Directly from any Person or Entity Involved...

The Centers for Medicare & Medicaid Services (CMS) on May 19, 2014, adopted a final rule that significantly revised Medicare Advantage (MA) and Part D prescription drug benefit program regulations (the “Final Rule”). One of...more

FCPA Enforcement Against Broker-Dealers: A New Headache For CCOs

In 2010, Wall Street shuddered when it was disclosed that the SEC had launched an inquiry into financial institutions, investment banks and private equity firms for potential FCPA violations involving interactions with...more

Broker-Dealers Cross Into FCPA Territory

The recent prosecution of two registered broker-dealers and a Venezuelan government official for FCPA violations underscores a point I often make – nothing good ever happens when the government has a reason to look around in...more

FCPA Broker-Dealer Case Highlights Compliance Risks for Financial Institutions

Last week saw a significant Foreign Corrupt Practices Act (FCPA) enforcement action against employees of a US broker-dealer, who are alleged to have bribed a Venezuelan government official to direct brokerage to the firm. The...more

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