The Justice Insiders Podcast - The Ever-Expanding Net: Corporate Compliance in an Era of Increasing Trade Sanctions and Restrictions
False Claims Act Insights - Are All Healthcare “Kickbacks” Subject to FCA Liability?
Episode 333 -- The Boeing Proposed Plea Agreement
DOJ’s New Self-Disclosure Policy and Corporate Whistleblower Awards Pilot Program
False Claims Act Insights - Assessing the Fallout from a Thermonuclear FCA Verdict
FCPA Survival Guide - Step 8 - Investing in Compliance
Exploring the AI and Crypto Intersection
The Justice Insiders Podcast: Jarkesy’s Implications for the Administrative State
The Presumption of Innocence Podcast: Episode 41 - The Dynamics of Decision-Making: Psychology and the Criminal Justice System
INTERPOL and Child Kidnapping Cases. What are INTERPOL’s Abilities and Limitations?
False Claims Act Insights - Eureka! Government Investigators Seek Out Research Misconduct
The Justice Insiders Podcast - AI-Washing: Everything Old Is New Again
The CFPB and State AGs Act Jointly Against Online Educational Company
Will the U.S. Have a GDPR? With Rachael Ormiston of Osano
Episode 328 -- Sanctions Enforcement Risks and Redlines
FCPA Survival Guide: Step 3 - Extensive Remediation
Episode 324 -- Third-Party Risks and Sanctions Compliance
Compliance Tip of the Day – Compliance Lessons from the Albemarle FCPA Enforcement Action
The Presumption of Innocence Podcast: Episode 38 - A Blueprint for Compliance: The Fraud Pentagon Theory
Episode 323 - Carlos Villagran Discusses Rebuilding a Corporate Culture After a Crisis
This article identifies themes we have observed in recent public formal enforcement actions issued to institutions by the US federal bank regulatory agencies (Agencies) — the Board of Governors of the Federal Reserve System...more
The recent bank regulatory Joint Statement and request for information (RFI) on third-party deposit relationships and bank-fintech partnerships emphasize afresh regulators’ long-standing concern with financial institutions’...more
We thank you for joining us over the past three years and are pleased to resume our CFPB Bites of the Month series in 2023! Consumer financial services concerns continue to be front and center in the daily news cycles....more
In this article, we share a timeline of our monthly "bites" for 2022 applicable to the auto finance industry. So, what happened in 2022?...more
On Nov. 3, 2022, the SEC announced a consent order against a registered investment adviser (RIA) and its chief executive officer (CEO) for failing to reasonably supervise one of the RIA’s investment adviser representatives...more
We have made it a point previously in this blog to track developments of the SEC’s Regulation Best Interest (Reg BI), even speculating more aggressive enforcement actions could be coming due to certain Reg BI deficiency...more
Responding to a “concern” from Chief Compliance Officers (CCOs) to the purported increase in enforcement actions holding compliance personnel personally liable, the New York City Bar Association recently released a framework...more
We were recently reminded of how difficult it is to re-register for a position in the securities industry after being barred. See https://www.sec.gov/litigation/admin/2021/ia-5682.pdf. On February 9, 2021, the United...more
A long time ago, long before there existed any whistleblower statutes, I had a client – a CCO of a broker-dealer – who discovered some pretty funky trading at his firm. As he tells the story, when he went to see his boss (who...more
As the cannabis industry continues to evolve and generate capital raising and investment opportunities, the SEC Division of Enforcement will continue to closely keep watch and target the bad actors that new market...more
On January 8, 2021, the SEC issued a cease-and-desist order, Release No., 90875 (available here), formally resolving proceedings against Deutsche Bank AG. Deutsche Bank agreed to pay over $125 million as part of a global...more
We have frequently blogged here about the degree of attention that regulators pay to Chief Compliance Officers, and whether it is proper that they sometimes are named individually in Enforcement actions. And we are hardly...more
As should be clear to readers of this Blog, I find that Enforcement actions often provide the best guidance in terms of what regulators deem to be unacceptable conduct, which is very useful when dealing with subjective...more
The Consumer Financial Protection Bureau (CFPB, or the Bureau) has announced major changes to its organizational structure, placing enforcement operations under the effective control of supervision. If finalized, this will be...more
On October 6, 2020, the Commodity Futures Trading Commission (“CFTC”) issued a release describing its record-breaking enforcement year. The release noted that in fiscal year 2020 (“FY2020”), the CFTC filed more enforcement...more
SEC Charges Trust Company with Operating Unregistered Investment Companies and Failing to Register Securities Offerings. On September 30, the Securities and Exchange Commission (SEC) announced it had settled charges with...more
On August 19, 2020, the Commodity Futures Trading Commission (“CFTC”) issued three orders filing and settling charges against a bank with a provisionally registered swap dealer (the “Firm”) requiring the Firm to pay $127.4...more
Report on Research Compliance 17, no. 2 (January 23, 2020) - - More than two years after Ozgur Tataroglu’s paper was retracted, the HHS Office of Research Integrity found that it and two grant applications contained...more
Within a week of the ceremonial swearing in of its last commissioner, the now fully formed Commodity Futures Trading Commission (Commission or CFTC) issued 17 enforcement orders and filed one complaint. These initial...more
A Lincoln Financial Group subsidiary agreed to pay $650,000 to the Financial Industry Regulatory Authority (FINRA) to resolve allegations that it failed to implement sufficient security policies to protect confidential...more
The Commodity Futures Trading Commission (CFTC) recently brought its first enforcement action arising from the Dodd-Frank requirement that swap transactions be reported to a registered swap data repository (SDR). The CFTC has...more
In his prepared remarks for an appearance last month at the Exchequer Club, Consumer Financial Protection Bureau Deputy Director Steven Antonakes discussed the CFPB’s risk-based approach to supervision. (The Exchequer Club’s...more
Several high-profile corporate criminal investigations and prosecutions in Germany have led to the scrutiny of directors and officers for failure of controls and supervision. Several recent notable German enforcement actions...more