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Discipline Securities and Exchange Commission (SEC)

Thomas Fox - Compliance Evangelist

Farewell to The Hawk – Fair and Consistent Application of Discipline

In the Department of Justice’s (DOJ’s) Evaluation of Corporate Compliance Programs (Evaluation), Prong 8 Incentive and Disciplinary Measures it states: Incentive System – Consistent Application – Have the disciplinary actions...more

Thomas Fox - Compliance Evangelist

Hallmark 6-Incentives and Disciplinary Measures

The FCPA Guidance states, “In addition to evaluating the design and implementa­tion of a compliance program throughout an organization, enforcement of that program is fundamental to its effec­tiveness. A compliance program...more

Thomas Fox - Compliance Evangelist

Episode 155-Mara Senn on FCPA Investigations and the Decision to Self-Disclose

In this episode I visit with Mara Senn, a partner at Arnold & Porter on how to think through a FCPA investigation and she provides a decision making calculus on how to make a decision...more

The Volkov Law Group

Three Keys To An Effective Disciplinary Program

The Volkov Law Group on

The Justice Department and the SEC have underscored the importance of a company maintaining a clear disciplinary process so that executives, managers and employees are aware that a violation of the corporate code of conduct...more

Brooks Pierce

You Can Go Home Again, but It Could Be a Thorny Path

Brooks Pierce on

Spence Barasch knows. You’ll remember that the SEC barred him for a year from appearing and practicing before the Commission for violating federal conflict of interest rules. Barasch was an associate director in the...more

Katten Muchin Rosenman LLP

Corporate and Financial Weekly Digest - August 23, 2013

In this issue: - SEC, CFTC and FINRA Issue Joint Advisory on Business Continuity and Disaster Recovery Planning - FINRA Updates Private Placement Form and Issues FAQ - SEC Approves Amendments to FINRA...more

Morrison & Foerster LLP

FINRA Rule 4530 – Recent Revisions Remind Broker-Dealers of the Importance of the New Requirement to Report Internal Findings of...

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

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