News & Analysis as of

Financial Fraud Actions – The New SEC Staple?

With the creation last year of the Financial Reporting and Audit Task Force, the Commission is returning to one of its enforcement staples – financial statement fraud. Following then Chairman Levitt’s “Numbers Game Speech” in...more

Revisiting The Corporate Top-10 FCPA Enforcement Actions

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

New York AG Announces Chief Of New Financial Crimes Bureau

On January 17, New York Attorney General (AG) Eric Schneiderman announced that Gary Fishman will lead a new Criminal Enforcement and Financial Crimes Bureau. The bureau, which expands the Attorney General’s former Criminal...more

SEC Settles Financial Fraud Case

Two senior executives at Veolia Environmental Services Special Services, a U.S. subsidiary of Paris based multi-national Veolia Environment S.A., were named in and resolved a financial fraud case with the SEC. SEC v. Hohol,...more

What Compliance Program?

At a recent luncheon, a representative of the U.S. Attorney’s Office in Los Angeles made some remarks that are helpful to all companies, regardless of size or industry. The context for the comments by this Assistant U.S....more

Revolving Doors: Anthony Marshall Out Again

I talked earlier about fiduciary duty and the conviction of Anthony D. Marshall, the son of Brooke Astor, on charges that he breached that duty while handling her financial affairs at the end of her life. In a six-month...more

Bank Liability to Non-Customers in a Ponzi Scheme

The morning news reports flashes a report that your customer was actually a Ponzi scheme and defrauded numerous people. Of course, this is terrible news for the innocent victims, but, you ask yourself, could my bank be...more

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