FCPA Compliance and Ethics Report-Episode 32-the FCPA Year in Review, Individual Enforcement Actions
Trends in FCPA Compliance and Enforcement for 2014
What Is Driving Stepped Up Government Health Care Enforcement? – Interview with Hope Foster, Member, Mintz Levin
SEC News - Five Year Enforcement Limitation, FCPA Charges for Foreign Nationals, More...
Should Wall Street Fear Mary Jo White?
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
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
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 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
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
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
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
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
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
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
- 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
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
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
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
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
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
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
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 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
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
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
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
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
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
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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