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Ballard Spahr LLP

ICBC Agrees to Two Consent Orders for Alleged BSA/AML Deficiencies and Disclosure of Confidential Supervisory Information

Ballard Spahr LLP on

Recently, the Industrial and Commercial Bank of China Ltd. (“ICBC”) entered into two consent orders. The first consent order is with the New York State Department of Financial Services (the “NYDFS”) for alleged deficiencies...more

Holland & Knight LLP

SEC Proposes Substantial New Cybersecurity Requirements for Investment Advisers and Companies

Holland & Knight LLP on

Following U.S. Securities and Exchange Commission (SEC) Chairman Gary Gensler's recent speech directing the agency to expand cybersecurity requirements on regulated entities, the SEC on Feb. 9, 2022, voted to propose new...more

BCLP

FINRA Panel Bars Registered Individual for Failure to Produce Tax Transcripts Not In His Immediate Possession, But Rather...

BCLP on

In a recent decision by a FINRA Office of Hearing Officers Panel, FINRA barred a registered individual who failed to produce his personal IRS tax transcripts, which were not in his immediate possession but rather maintained...more

Thomas Fox - Compliance Evangelist

The Herbalife FCPA Enforcement Action: Part 1 – Introduction

Herbalife Nutrition Ltd (Herbalife) recently concluded a long running Foreign Corrupt Practices Act (FCPA) enforcement action with both the Department of Justice (DOJ) and Securities and Exchange Commission (SEC). Herbalife...more

The Volkov Law Group

Herbalife FCPA Settlement is An Important Reminder: Global Companies Need to Focus on Foreign Government Touchpoints

The Volkov Law Group on

As we look past the Herbalife FCPA settlement with DOJ and the SEC for $123 million to resolve FCPA bribery and books and records violations, we are reminded of the variety of foreign government touchpoints and FCPA risks....more

The Volkov Law Group

World Acceptance Corporation Settles FCPA Charges with the SEC for $21.7 Million

The Volkov Law Group on

World Acceptance Corporation (“WAC”), a US-based consumer loan company, agreed to pay the SEC $21.7 million for FCPA violations in Mexico.  WAC’s cited violations covered the full gamut of FCPA violations, including bribery...more

Thomas Fox - Compliance Evangelist

Alexion Pharmaceuticals FCPA Enforcement Action: Part 2 – Data Analytics

The same day that the 2020 Resource Guide was released, the Securities and Exchange Commission (SEC) announced it had settled a Foreign Corrupt Practices Act (FCPA) enforcement action involving Alexion Pharmaceuticals Inc....more

Thomas Fox - Compliance Evangelist

Alexion Pharmaceuticals FCPA Enforcement Action: Part 1 – The Bribery Schemes

The same day that the 2020 Resource Guide was released the Securities and Exchange Commission (SEC) announced it had settled a Foreign Corrupt Practices Act (FCPA) enforcement action involving Alexion Pharmaceuticals Inc....more

The Volkov Law Group

Alexion FCPA Violations: Lessons Learned (Part II of II)

The Volkov Law Group on

The Alexion Pharmaceutical SEC FCPA enforcement action represents another in the long line of enforcement actions against drug and device companies.  The drug and device industries have been – and will continue to be — easy...more

Ballard Spahr LLP

Consumer lender sets aside $21.7 million to settle Foreign Corrupt Practices Act probe

Ballard Spahr LLP on

South Carolina-based consumer lender World Acceptance Corporation announced recently that it had earmarked $21.7 million to resolve a Securities and Exchange Commission (SEC) probe into its compliance with the Foreign Corrupt...more

Kramer Levin Naftalis & Frankel LLP

Delaware Chancery Court Holds That Stockholders Had a “Proper Purpose” to Seek Board Materials From Opioid Distributor, and Orders...

In a 63-page decision issued on Jan. 13, 2020, in Lebanon County Employees’ Retirement Fund v. AmerisourceBergen Corporation, Vice Chancellor J. Travis Laster of the Delaware Court of Chancery found that stockholders of...more

Stinson - Corporate & Securities Law Blog

Rushed Earnings Release Results in SEC Enforcement Action

Calumet Specialty Products Partners, L.P. disclosed in its third-quarter 2017 Form 10-Q that, beginning in September 2017, Calumet’s implementation of its new enterprise resource planning (“ERP”) system had resulted in...more

The Volkov Law Group

Under Armour Under DOJ and SEC Investigation For Revenue Recognition Scheme

The Volkov Law Group on

The Justice Department and the SEC have launched criminal and civil accounting fraud investigations against Under Armour.  The sportswear maker has been suffering a rapid revenue decline over the last few years....more

Skadden, Arps, Slate, Meagher & Flom LLP

Inside the Courts – An Update From Skadden Securities Litigators - September 2019

This quarter’s issue includes summaries and associated court opinions of selected cases principally decided between May and August 2019....more

Holland & Knight LLP

Petrobras Agrees to Pay More Than $1.8 Billion for Facilitating FCPA Violations

Holland & Knight LLP on

• Four years ago, Brazilian authorities began Operation Car Wash, a wide-ranging and still ongoing corruption and money laundering investigation that has spanned 11 countries. • The fallout continues with a recent U.S....more

The Volkov Law Group

Sanofi Coughs Up $25 Million to Settle SEC FCPA Charges

The Volkov Law Group on

Well, add another pharmaceutical company to the FCPA healthcare “sweep.” Frankly, the term “sweep” makes it sound like a coordinated enforcement effort – instead, it is more accurate to think of it as multiple prosecutions...more

The Volkov Law Group

Mondelez FCPA Enforcement Action — An Abuse of Prosecutorial Discretion?

The Volkov Law Group on

The first FCPA enforcement action for 2017 landed with very little fanfare. The SEC reached a settlement with Mondelez International for $13 million. The facts surround the hiring of an agent in India and the failure of...more

The Volkov Law Group

FCPA Enforcement Ramping Up Against Private Equity and Hedge Funds (Part III)

The Volkov Law Group on

The Och-Ziff settlement has now set the stage for the Justice Department and the SEC to focus its enforcement eye on the private equity and hedge fund industry. The Och-Ziff action was initiated in response to the SEC’s...more

The Volkov Law Group

DOJ and SEC Deliver Body Blow to Private Equity and Hedge Funds: Och-Ziff Settles FCPA Violations for $412 Million (Part I)

The Volkov Law Group on

The Justice Department and the Securities Exchange Commission delivered a powerful FCPA enforcement message to private equity and hedge funds. Och-Ziff settled with the DOJ and SEC for total penalties of $412 million....more

Orrick, Herrington & Sutcliffe LLP

This Cold Bud Is For You: SEC Sanctions Anheuser-Busch for “Chilling” Employee from Communicating with SEC

On September 28, 2016, the SEC announced that Anheuser-Busch agreed to pay $6 million to settle charges of Foreign Corrupt Practices Act and Dodd-Frank whistleblower violations. The SEC’s order stated that AB InBev violated...more

Thomas Fox - Compliance Evangelist

Anheuser-Busch InBev and Lessons in Joint Venture FCPA Compliance

Just in time for National Beveridge Day comes the Foreign Corrupt Practices Act (FCPA) enforcement action involving Anheuser-Busch InBev (ABI), where the company paid $6 million to settle charges that it violated the FCPA and...more

The Volkov Law Group

Five Key Takeaways from Key Energy’s SEC FCPA Settlement

The Volkov Law Group on

The SEC, last week, announced its $5 million settlement with Key Energy. As always, FCPA settlements contain important examples of enforcement priorities and policies. Key Energy’s recent settlement is an example of the...more

The Volkov Law Group

DOJ and SEC Collect $22 Million from LAN Airlines for Conduct in Resolving Labor Dispute

The Volkov Law Group on

Last week, the Justice Department and the SEC announced parallel FCPA settlements totaling $22 million in fines, penalties and disgorgement against LAN Airlines, a Chile-based airline, for conduct in resolving a labor dispute...more

Manatt, Phelps & Phillips, LLP

Corporate Investigations & White Collar Defense - October 2015

"Wherefore Art Thou Due Process?" Part III - Why it matters: It is time for another installment in our continuing "Wherefore Art Thou Due Process?" coverage into the ongoing constitutional challenges to the SEC's...more

Blank Rome LLP

SEC FCPA Enforcement Action against Goodyear and Investigation of Mondelez International Provide Valuable Lessons for U.S....

Blank Rome LLP on

Action Item: The Securities and Exchange Commission’s enforcement action against Goodyear Tire & Rubber Company and its investigation of Mondelez International provide key lessons to U.S. companies seeking to acquire foreign...more

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