AML BSA and Sanctions Compliance Part II of II June 24, 2014
Thomson Reuters Session - April: Investment Management, Hedge Funds & Registered Mutual Funds: What's Happening Now?
FCPA Compliance and Ethics Report-Episode 31-the FCPA Year in Review, Corporate Enforcement Actions
FCPA Compliance and Ethics Report-Episode 30-Interview with the FCPA Professor-Part 2
Building an Integrated Third Party Due Diligence System Initial Screening to Audits
Fine Tuning Your Anti Corruption Compliance Program
FCPA Compliance and Ethics Report-Episode 21 Update on Current Enforcement Actions, Investigations and Settlement Negotiations
Trends in FCPA Compliance and Enforcement for 2014
FCPA Compliance and Ethics Report-Episode 14 with the FCPA Professor
The New Normal: Taking Responsibility for Your Vendors
Lessons Learned from the BizJet Executives FCPA Enforcement Actions
Suzanne Folsom on Corporate Compliance Issues -
Transaction Monitoring Under the FCPA
In this era of aggressive FCPA enforcement, there are critics who have suggested that the Department of Justice should concentrate its prosecutions on individuals rather than imposing ever-increasing criminal fines on...more
Penny stock companies have been much in the news recently. They can be tough entities for law enforcement to look into given that their officers and directors are often not inclined to cooperate with government...more
The SEC’s insider trading probe regarding the House Ways and Means Committee and a senior staff member, also involves 44 investment funds and other entities, according to a Bloomberg news report citing recently filed court...more
On the eve of a trial which was scheduled to begin this week, the Securities and Exchange Commission settled a civil Foreign Corrupt Practices Act (FCPA) case it brought against two former oil services executives. The case...more
The unblemished record of the Manhattan U.S. Attorney’s Office in insider trading cases came to an end this week with the acquittal of Rengan Rajaratnam, brother of the convicted Galleon Fund founder. This is the first loss...more
Although passed in 1977, the Foreign Corrupt Practices Act (FCPA) was not significantly enforced until 2005. Since then, the U.S. Department of Justice (DOJ) and Securities and Exchange Commission (SEC) have made up for the...more
The SEC was about to try its first FCPA case. Then the Commission settled, agreeing to drop the bribery charges as well as its demand for monetary sanctions. That ended the case against two Nobel Corporation executives SEC v....more
In a holiday shortened week, dark pools were again a focus for regulators. This week FINRA sanctioned Goldman Sachs in connection with the operation of its dark pool....more
With over $1.5 billion in fines assessed by the U.S. Securities and Exchange Commission for violations of the Foreign Corrupt Practices Act (FCPA) since 2010, corruption concerns are playing a larger role in corporate...more
In this issue:
- SEC Warns Private Equity Fund Advisers about Compliance Shortcomings
- Why the 50 Percent Rule Deserves 100 Percent Attention
- Exactly How Much Omega-3 Is in There?
Anti-Corruption Digest is an update distributed on a monthly basis by Dorsey & Whitney providing a summary of the latest developments in anti-corruption enforcement activity around the world.
In This Issue:
Welcome to the May 2014 edition of Red Notice, a publication of Akin Gump Strauss Hauer & Feld LLP.
This month, on the anticorruption front, Avon Products, Inc. (“Avon”) agrees to pay USD $135 million to settle a...more
Federal regulators have been particularly aggressive in enforcing the Foreign Corrupt Practices Act (FCPA), making it crucial for companies to take anti-corruption training seriously.
Beauty products giant Avon...more
Several recent multi-million dollar settlements with companies to resolve bribery violations illustrate how the Securities and Exchange Commission (SEC) is keeping its focus on internal controls and the accounting provisions...more
We all like organized lists. Short and sweet is easier to understand and ignore nuances. Even in our FCPA world, we track settlements by a top-10 lost. The concept of a top-10 predated David Letterman’s top-10 lists, and...more
The Marx Brothers’ movies will live in infamy – they were hilarious, creative, and always relevant.
One of my favorites was A Day at The Races, and the scene that applies with force to FCPA enforcement – Chico was...more
A. Opinion Releases -
1. Gifts -
In the early 1980s the Department of Justice (DOJ) issued three Opinion Releases related to gifts under the Foreign Corrupt Practices Act (FCPA). While these Opinion Releases are...more
The HP FCPA settlement was not your run-of-the-mill enforcement action. The blogosphere has been filled with different analyses and interpretations. Client alerts have been taking shots at coming up with original ideas and...more
Recent disputes and controversies involving Chinese subsidiaries of foreign pharmaceutical companies have sounded warning bells on legal and ethical issues regarding participation in China’s rapidly growing and evolving...more
On March 19, the DOJ announced that Marubeni Corporation, a Japanese trading company, agreed to plead guilty to violating the FCPA by participating in a seven-year scheme to bribe high-ranking government officials in...more
On Oct. 1, 2013, the Securities and Exchange Commission (SEC) announced that it had awarded more than $14 million to an unidentified whistleblower who provided information leading to a successful enforcement action — by far...more
The 2013 calendar year saw several significant developments in the enforcement of the Foreign Corrupt Practices Act (FCPA). The United States Department of Justice (DOJ) and Securities and Exchange Commission (SEC) combined...more
The importance of a company’s response to a Department of Justice (“DOJ”) investigation into possible violations of the Foreign Corrupt Practices Act (“FCPA”) was highlighted last week when Marubeni Corporation (“Marubeni”)...more
The debate over the efficiencies of Deferred Prosecution Agreements (DPAs) continued this week with additional criticism of their use. I have argued that DPAs are in a corporation’s interest because they can bring certainty...more
Foreign Corrupt Practices Act (FCPA) enforcement activity in 2013 was robust, with DOJ and the SEC bringing 31 new FCPA enforcement actions, exceeding 2012’s total of 25. Total penalties amounted to more than...more
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