Corruption, Crime and Compliance - “The New FCPA”: Sanctions and Export Control Enforcement and Compliance
Giving Compliance Advice
Corruption, Crime, & Compliance - Five Steps to Enhance Your Sanctions Compliance Program
Corruption, Crime and Compliance - Deep Dive Into Wells Fargo’s $30 Million OFAC Settlement
FINCast Ep. 36 – Regulators’ Roundtable to Forecast 2023
Guidepost in Motion EP25: State of Compliance with Alixandra Smith Part 2
FCPA Compliance Report - Matt Silverman on Potential Sanctions Against Russia
Argentina: A Look at the Case of Lázaro Báez - Laundering the Proceeds of Corruption and Tax Fraud
Nota Bene Podcast Episode 131: U.S. Sanctions Against Russia: Valid or Ineffective Economic Policy? with Fatema Merchant and Mario Torrico
Compliance into the Weeds - SAP Trade Sanctions Enforcement Action
What to Expect from the Biden Administration
A Look Ahead at the Biden Administration’s Regulatory and Enforcement Priorities
Compliance Perspectives: The German Corporate Sanctions Act
Episode 153 -- The Mighty Amazon Falls to OFAC Enforcement Sword
Navigating an Increasingly Complex Sanctions Landscape: New Exposures for Corporations and Shipping
Episode 120: Interview of NAVEX Global Third-Party Risk Officials: Chris Bailey and Stephen Gooding
U.S. policy reversal allows suits in U.S. courts and visa denials, for “trafficking” in confiscated property in Cuba
Jones Day Presents: Considerations in Implementing Blockchain Technology
This Week in FCPA-Episode 80, The Last Jedi Edition
The Perils of Compliance with the Russia Sanctions Program
On January 16, the U.S. Securities and Exchange Commission (SEC) announced a record $18 million sanction against JP Morgan for Rule 21F-17(a) violations, sending the strongest message yet that the SEC is cracking down on...more
Global political and business leaders have purported ambitious climate-focused goals for the decades ahead, such as eliminating landfill waste by 2030, transitioning to 100% renewable energy use by 2035, and achieving...more
A two-year campaign to create an effective law incentivizing whistleblowers to report money laundering and sanctions busting has ended with a stunning and surprise victory for whistleblowers. It started in December 2020 when...more
Nearly 10 years after former employee Howard Wilkinson blew the whistle on Danske Bank, the U.S. Department of Justice (DOJ) and Securities and Exchange Commission (SEC) have issued over $2 billion in penalties against the...more
2017 will most likely be remembered as a year of transition, as the Securities and Exchange Commission’s enforcement actions indicate, at least in the near term, an emphasis on specific initiatives and retail investor...more
For the first time in my memory, the Congress passed a joint resolution to disapprove a final regulation of a federal agency—in this case the CFPB and the rule was related to arbitration clauses in contracts for consumer...more
Stephanie Avakian and Steven Peikin, the new Co-Directors of the U.S. SEC Enforcement Division (“Division”), released a report on November 15, 2017, summarizing the Division’s enforcement activity for the fiscal year ending...more
Last Friday, Judge Richard Story (USDC, N.D. Ga.) entered an order in Consumer Financial Protection Bureau v. Universal Debt Solutions, LLC, et al., granting a defendant’s motion for Rule 37 discovery sanctions and striking...more
This quarter’s issue includes summaries and associated court opinions of selected cases principally decided between February 2017 and April 2017. The cases address developing trends in class actions, ERISA, fiduciary duties,...more
Globalization has connected people, companies, and products across national borders more than ever. Goods and services developed in one part of the world are readily available in other parts of the world and technology is...more
Non-Enforcement - SEC Decides Against Mounting an Appeal in Koch Ruling - The July 2015 ruling by the D.C. Circuit Court in Koch v. SEC will apparently not be challenged by the SEC. The Court ruled in that...more
Following the D.C. Circuit’s July 14, 2015 decision in Koch et al. v. Securities and Exchange Commission, No. 14-1134 (D.C. Cir. July 14, 2015), which held that the SEC could not retroactively punish an investment advisor for...more
SEC-Sanctioned Trader Began Alleged Spoofing After Complaining About Spoofing by Others to NYSE - Eric Oscher and Briargate Trading, LLC, a company 50 percent owned by Mr. Oscher, agreed to pay an aggregate fine of US...more
On September 29, the U.S. Commodity Futures Trading Commission announced that it would issue an award of approximately $290,000 to whistleblowers for providing valuable information about violations of the Commodity Exchange...more
Regulatory Developments - NYDFS Announces Approval of First BitLicense Application from a Virtual Currency Firm: The New York State Department of Financial Services (NYDFS) announced Sept. 22 that it has approved...more
FC Stone Companies and Goldman Sachs Receive Largest Fines in CME Group’s 27 Disciplinary Actions Cascade: CME Group handed down sanctions in 27 separate disciplinary actions last week for alleged violations of rules...more
The Securities Exchange Commission announced June 18 the first major wave of underwriter sanctions under its Municipalities Continuing Disclosure Cooperation (“MCDC”) Initiative. The SEC sanctioned 36 municipal underwriting...more
FINRA’s newly revised Sanction Guidelines, effective immediately, signal that the upward trend in sanctions against broker-dealers is likely to continue. The Sanction Guidelines, which establish the range of sanctions...more
Think of a U.S.-headquartered multinational when it receives an allegation of serious misconduct at one of its overseas operations. Maybe the company whistleblower hotline just got a tip that a secretary in the Buenos Aires...more
The CFTC Exercises Expanded Jurisdiction Over Retail Transactions in Physical Commodities. Title VII of the Dodd-Frank Act of 2010 amended the Commodity Exchange Act (CEA) to add new authority over certain leveraged,...more
What I’m about to say is grossly oversimplified, but here goes: The Dodd-Frank Act’s whistleblower provisions have two primary prongs. The first says that an individual who voluntarily provides the SEC with original...more
As reported in the May 2014 edition of Legal News: Investment Management Update, the SEC has made cybersecurity readiness a high-priority item to review when it conducts examinations of registered broker-dealers and...more
In this issue: - Concurrent Resolution of FCPA, Export Controls and Sanctions Violations Demonstrates Close Cooperation of Federal Agencies - Five Agencies Issue Final Volcker Implementation Rules; Small Banks...more
On June 12, 2013, the SEC issued the second-ever whistleblower bounty award pursuant to Section 922 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank) in connection with SEC v. Andrey C. Hicks and...more
The Securities and Exchange Commission’s Annual Report on the Dodd-Frank Whistleblower Program, released November 2012, provides the first complete year of data on the activities of the Office of the Whistleblower (“OWB”)...more