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FCPA Compliance and Ethics Report-Episode 145-SEC Enforcement of the FCPA, Part II
On November 14, 2023 the Securities and Exchange Commission (SEC) released its annual Office of the Whistleblower Report to Congress for fiscal year 2023 (October 1, 2022-September 30, 2023). This report highlighted several...more
Approaches and developments - The Cayman Islands has long been a leading offshore jurisdiction for investment funds, as well as a significant global financial centre overall. It is therefore not surprising that, reflecting...more
By 30 June 2022, Formula 1 teams will have to submit their (interim) financial information to the International Automobile Federation ("FIA") under the Formula 1 Financial Regulations ("Financial Regulations")...more
Commission staff highlight key developments and successes in the SEC enforcement program. As they do every year, senior officials from the US Securities and Exchange Commission (SEC or the Commission), including current...more
In this episode which is Part II of my look at SEC enforcement of the FCPA, I consider whether profit disgorgement is available to the SEC in a strict liability enforcement action of violation of internal controls. ...more
Even more notable to securities practitioners than the attendance of Mark Cuban at this year’s SEC Speaks event (held in Washington, D.C. on February 21 22, 2014) was the start-to-finish focus of the Enforcement Division on...more
The SEC likes to reorganize, refocus and reenergize. In the last ten years, the SEC has continued to reinvent itself. Whether it has been effective or not, is still up for questioning....more
Andrew Ceresney, SEC Co-Director of the Division of Enforcement, recently gave a talk on financial reporting and accounting fraud. Mr. Ceresney reviewed statistics showing declines in restatements and accounting fraud cases....more