Two recent Foreign Corrupt Practices Act (FCPA) actions – a Department of Justice (DOJ) Opinion letter and an SEC settlement – underscore key diligence questions that legal and compliance departments should address when...more
9/11/2023
/ Civil Monetary Penalty ,
Compliance ,
Corporate Counsel ,
Department of Justice (DOJ) ,
Disgorgement ,
Federal Contractors ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Official ,
Meal and Entertainment Expenditures ,
New Regulations ,
Opinion Letter ,
Pre-Judgment Interest ,
Securities and Exchange Commission (SEC) ,
Securities Violations ,
Travel Expenses
A key temporary bankruptcy related response to the pandemic has been re-implemented and extended with the passage of the Bankruptcy Threshold Adjustment and Technical Corrections Act (the “Act”) which extends the increase in...more
A key bankruptcy-related response to the pandemic has ended as the increased debt limits under subchapter V of chapter 11, passed by Congress in the CARES Act, have expired. In an effort to provide bankruptcy relief and...more
The Securities and Exchange Commission (“SEC” or “Commission”) has released a proposal to amend Exchange Act Rule 3b-16, Regulation ATS, and Regulation SCI. Criticized by SEC Commissioner Hester Peirce as “too wide-ranging”...more
3/11/2022
/ Alternative Trading System (ATS) ,
Blockchain ,
Comment Period ,
Cryptocurrency ,
Decentralized Finance (DeFi) ,
Distributed Ledger Technology (DLT) ,
Proposed Amendments ,
Proposed Rules ,
Regulation SCI ,
Securities and Exchange Commission (SEC) ,
Securities Exchange Act
Investigators with the U.S. Department of Justice reportedly are investigating energy pricing benchmarks published by Platts, targeting suspected manipulation of deal prices provided by individual traders.
According to...more
10/6/2021
/ Benchmark Pricing ,
Commodities Traders ,
Compliance ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Fraud ,
Government Investigations ,
Libor ,
Market Manipulation ,
Oil Prices ,
Price Manipulation ,
Racketeering ,
Risk Management ,
S&P ,
Traders
On June 3 of this year, the Biden Administration made plain its commitment to fighting corruption around the world, releasing a document identifying the fight against corruption “as an economic and national security priority”...more
8/25/2021
/ Anti-Corruption ,
Biden Administration ,
Blocked Person ,
Compliance ,
Corporate Transparency Act ,
Cross-Border Transactions ,
Enforcement ,
FinCEN ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Entities ,
Foreign Official ,
Internal Controls ,
Latin America ,
National Security ,
NDAA ,
Office of Foreign Assets Control (OFAC) ,
Publicly-Traded Companies ,
SDN List ,
White Collar Crimes