Enforcement

News & Analysis as of

Nursery Rhymes, A Chinese Proverb, The HP FCPA Enforcement And The Myth Of The Rogue Employee

As my friend and colleague Jay Rosen is want to remind us, he continually learns much about compliance and ethics from his Kindergarten-aged daughters. I submit that you need only look to children’s nursery rhymes in the...more

Anti-Corruption Digest - April 2014

Welcome to Dorsey & Whitney’s monthly Anti-Corruption Digest. Anti-corruption enforcement crosses boundaries like no other, so keeping up to date is more important than ever. In this digest, we draw together news of...more

Recent Study Finds Positive Momentum in Global Anti-Bribery Efforts

Since 2003, U.S. enforcement has dominated international anti-bribery efforts, with nearly twice as many formal foreign bribery actions as all other countries combined. However, according to data recently released in TRACE...more

OSHA Update: Aggressive OSHA Enforcement and "OSHA Jail"

OSHA has proposed its budget for fiscal year 2015 and there are already many contentious positions being taken regarding what had been hailed as overly aggressive enforcement positions by OSHA. Examples of overzealous...more

Tales From The Crypt - Rule No. 7 - Actions Speak Louder Than Words

Ed. Note-I inadvertently ran Tale From The Crypt, Rule No. 8 out of order, so today we present Rule No. 7, which reminds us that Mom was right, actions do speak louder than words... This Tale from our Crypt reminds us...more

Implications of U.S. Sanctions Program on Intellectual Property Owners

To advance U.S. foreign policy and national security objectives, the U.S. maintains laws and regulations that impose economic sanctions against certain countries, individuals, and entities (the "U.S. Sanctions Program"). 31...more

The SEC’s Continuing Investigation Regarding Carter’s, Inc.

Carter’s Inc. is the SEC investigation that just keeps on producing cases. Recently former firm vice president Richard Posey settled insider trading charges with the Commission after pleading guilty to one count of conspiracy...more

Three Important TCPA Developments

Within the course of two weeks, there have important modifications in the way that the TCPA is applied and enforced. 1. In the Matter of GroupMe Inc./Skype Communications S.A.R.L., FCC Declaratory Ruling, FCC 14-33...more

Charles Duross: FCPA reform, DOJ trials and the revolving door

What matters were you particularly proud to have been involved in during your time at the DoJ? I’m proud of all of it but I think there are probably a couple of specific matters that stand out in my mind. The first...more

Securities And Exchange Commission Creates New Private Fund Unit Dedicated To Examination Of Private Equity And Hedge Funds

On April 7, 2014, it was announced that the United States Securities and Exchange Commission (SEC) has created a new private fund unit dedicated to the examination of private equity and hedge funds....more

SEC Initiative Encourages Continuing Disclosure Violation Self-Reporting By Issuers And Underwriters

HIGHLIGHTS - - The Municipalities Continuing Disclosure Cooperation Initiative (MCDC Initiative) begun by the SEC's Enforcement Division encourages issuers, borrowers or underwriters to self-disclose potential...more

Court Rejects Wyndham’s Challenge to FTC’s Data-Security Enforcement Authority

In June 2012, the Federal Trade Commission (FTC) filed suit under Section 5 of the FTC Act (Section 5) against the Wyndham hotel chain (Wyndham) following a security breach that led to the theft of payment card data for...more

New Round of HIPAA Audits To Begin Later This Year

The Department of Health and Human Services’ Office for Civil Rights (OCR) recently announced it will resume its HIPAA compliance audit program — launched as a pilot program in 2012 — on a permanent basis in 2014. In...more

SEC Steps Up Scrutiny of Municipal Bonds: Recently Filed Enforcement Actions

As Bret Leone-Quick discussed in a post last week, the SEC has been stepping up its scrutiny of municipal bond offerings. Indeed, in the last year the SEC has filed a number of enforcement actions against municipal bond...more

AML Enforcement Jitters And Due Diligence

The Justice Department and the financial regulatory agencies have sent a strong message of enforcement, suggesting that financial institutions are not adequately implementing AML compliance controls....more

DOJ's First Opinion Release Shows Cautious Moves Amidst Aggressive FCPA Enforcement

The Foreign Corrupt Practices Act (FCPA) prohibits giving or offering anything of value to any foreign official with a corrupt intent to assist in obtaining or retaining business. Enforcement of FCPA compliance by the...more

This Week In Securities Litigation (Week ending April 4, 2014)

High speed trading and insider trading were key topics this week. Author Michael Lewis released a new book on high speed trading and, in an interview claimed the markets are “rigged.” The Commission focused on insider...more

SEC Correction: Reinstating an Exception to an Exception to an Exception

No one could be blamed for having difficulty understanding the intricacies of the rules under Section 17(d) of the Investment Company Act, the statute that prohibits “joint transactions” without an SEC order. At the end of...more

FCPA: A Focus On Individuals

FCPA enforcement officials have repeatedly emphasized that they intend to focus on individuals as an effective means of halting possible violations. A case unsealed yesterday underscores this point. The action, based...more

Nevada Federal Court Holds Tribal Lender Subject to FTC Jurisdiction

Adopting a magistrate judge’s report and recommendations, the United States District for the District of Nevada held that the FTC has enforcement jurisdiction over tribal payday lenders. ...more

Division of Investment Management Lists 2013 Accomplishments; Sets 2014 Agenda

The SEC’s Division of Investment Management summarized its activities in 2013, highlighting its intensified rulemaking program, efforts to identify new and emerging risks and its disclosure initiatives. The Division also took...more

Aggressive U.S., UK Anti-Bribery Enforcement Expected in 2014

According to a recent webinar sponsored by the law firm Hogan Lovells, anti-corruption experts expect to see an increased number of investigations this year under both the U.S. Foreign Corrupt Practices Act (FCPA) and the UK...more

DOJ and SEC Representatives Tackle Pressing Anti-Corruption Issues in 2014

On March 20th and 21st, U.S. regulators, practioners, and other anti-corruption industry professionals gathered in Washington, D.C. for the Second Annual Global Anti-Corruption Congress. The Congress featured speakers,...more

A Compilation of Actions - April 01, 2014

In a recent SEC no-action letter (RS Global Natural Res. Fund, SEC no-action letter, available 3/6/14), the SEC stated that it would take a non-enforcement position if a SEC registered investment adviser to a fund registered...more

Emphasis On Enforcement

In back-to-back keynote addresses Monday to the Securities & Financial Markets Association’s annual Compliance & Legal meeting, SEC-Chair Mary Jo White and Southern District of New York US Attorney Preet Bharara renewed the...more

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