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Commodity Futures Trading Commission Discusses Approach to Virtual Currency Futures Markets

by Shearman & Sterling LLP on

The Commodity Futures Trading Commission has released a backgrounder on the federal oversight of virtual currencies and its approach to regulating the virtual currency derivatives markets. Because virtual currencies have been...more

Day 17 of 31 Days to a More Effective Compliance Program-Managing Your Third Parties

by Thomas Fox on

The building blocks of any compliance program lay the foundations for a best practices compliance program. For instance, in the lifecycle management of third parties, most compliance practitioners understand the need for a...more

Your Daily Dose of Financial News

by Robins Kaplan LLP on

More trouble for the embattled British PM Theresa May. We learned yesterday that Britain’s second-largest construction firm—Carillion—was forced into liquidation after amassing a staggering $1.35 billion in debt. The downfall...more

Compliance Man Goes Global - Episode 8: Tough Questions

by Thomas Fox on

Welcome to Episode 8 of Compliance Man Goes Global podcast of FCPA Compliance Report International Edition. In this episode, we will focus on tough questions, which Compliance officers need to address. We will explore this...more

Day 16 of 31 Days to a More Effective Compliance Program-the Third-Party Risk Management Process

by Thomas Fox on

As every compliance practitioner is well aware, third parties still present the highest risk under the Foreign Corrupt Practices Act (FCPA). The Department of Justice Evaluation of Corporate Compliance Programs devotes an...more

Regulators Continue to Scrutinize Initial Coin Offerings

by Carlton Fields on

As reported in the most recent issue of Expect Focus, the SEC issued an investigative report in July cautioning market participants that distributed ledger (blockchain) technology-based offers and sales of digital "tokens" or...more

Day 15 of 31 Days to a More Effective Compliance Program-How Do You Evaluate a Risk Assessment?

by Thomas Fox on

After you complete your risk assessment, you must then translate it into a risk profile, as Rick Messick has noted, to estimate where bribery is likely occur, so prevention efforts will be properly targeted. Ben Locwin...more

Day 14 of 31 Days to a More Effective Compliance Program- Risk Assessments

by Thomas Fox on

One cannot really say enough about risk assessments in the context of an anti-corruption program. Since at least 1999, in the Metcalf & Eddy enforcement action, the DOJ has said that a risk assessment, which measures the...more

Day 13 of 31 Days to a More Effective Compliance Program

by Thomas Fox on

In the Department of Justice’s Evaluation of Corporate Compliance Programs, Prong 8 Incentive and Disciplinary Measures it states: Incentive System – Consistent Application – Have the disciplinary actions and incentives been...more

More Of An SRO - FINRA Unveils Its Priorities For 2018

On January 8 the Financial Industry Regulatory Authority (FINRA) published its Annual Regulatory and Examination Priorities Letter, which highlights key areas of focus for FINRA in the coming year. ...more

Your Daily Dose of Financial News

by Robins Kaplan LLP on

The Times explores the $27 billion in fixed-income-trading income that has seeped out of Wall Street over the past 5 years thanks to “a combination of tough regulations, new technologies, calm markets and changing customer...more

Chris Lazarini Comments on Qualifiers of Control Person Liability under Exchange Act §20(a)

by Bass, Berry & Sims PLC on

Bass, Berry & Sims attorney Chris Lazarini commented on a case involving alleged violations of federal and state securities laws and state common law in an alleged scheme to defraud customers and investors in several...more

Orrick's Financial Industry Week In Review

Chairman Giancarlo Statement on Virtual Currencies - On January 4, 2018, the Commodity Futures Trading Commission (CFTC) Chairman, J. Christopher Giancarlo, issued a statement on virtual currencies. "The CFTC's Market Risk...more

Initial Coin Offerings and Cryptocurrencies Will be a Priority for FINRA in 2018

In a ten page letter that previews the Financial Industry Regulatory Authority’s (FINRA) priorities for 2018, initial coin offerings (ICOs) and transactions involving cryptocurrencies....more

Day 12 of 31 Days to a More Effective Compliance Program-Financial Incentives for Compliance

by Thomas Fox on

One of the areas that many companies have not paid as much attention to in their compliance programs is compensation. However, the DOJ and SEC have long made clear that they view monetary structure for compensation, rewarding...more

This Week in FCPA-Episode 84, the Playoffs are Here (for the Patriots) edition

by Thomas Fox on

In this episode, Jay Rosen and myself take a look at some of the top compliance stories over the past week. 1. Does Free Speech exist at the office? Can you tell your boss what you think of them? Ben DiPietro looks at a...more

Could the Crypto-Rouble Spell Crypto-Trouble for Sanctions?

Russian President Vladmir Putin has directed his government to develop a state-backed cryptocurrency, according to a Financial Times report published on January 2nd. A Putin advisor says that the “Crypto-rouble” could be used...more

Financial Services Weekly News - January 2018

by Goodwin on

Editor's Note - A Busy Holiday Season. We hope that all of you had a happy holiday season and wish everyone a happy, healthy and prosperous new year. While the Roundup has been on hiatus during the holidays, the federal...more

Your Daily Dose of Financial News

by Robins Kaplan LLP on

In naming Gregory Abel and Ajit Jain vice chairs, Berkshire Hathaway took another big step this week in laying out LAWB (Life After Warren Buffet)....more

Across the Board-Episode 12, Prudent Discharge of Board Compliance Obligations

by Thomas Fox on

In this episode I consider the obligations of a Board of Directors for a compliance program and how they may prudently discharge that obligation under Delaware case law, SEC regs, US Sentencing Guidelines and the Ten...more

Day 15 of 31 Days to a More Effective Compliance Program-How Do You Evaluate a Risk Assessment?

by Thomas Fox on

After you complete your risk assessment, you must then translate it into a risk profile, as Rick Messick has noted, to estimate where bribery is likely occur, so prevention efforts will be properly targeted. Ben Locwin...more

Your Daily Dose of Financial News

by Robins Kaplan LLP on

AT&T has dropped plans to sell the Mate 10—the newest smartphone from China’s Huawei Technologies—just before the partnership was to be announced. AT&T gave no reasons for its abrupt reversal, but lawmakers have recently...more

FINRA Targets ICOs and Digital Currencies in Annual Broker Exam Priorities Letter

by Goodwin on

On January 8, 2018, the Financial Industry Regulatory Authority (FINRA) released its 2018 Annual Regulatory and Examination Priorities Letter (Exam Priorities Letter) for its broker-dealer members. In the Exam Priorities...more

SEC Cyber Unit Increases Efforts to Regulate Crypto-Currency

by Nossaman LLP on

Based on how 2017 ended, entities and individuals in the crypto-currency markets should expect increased scrutiny from the United States Securities and Exchange Commission (“SEC”) in 2018. The SEC’s Cyber Unit commenced its...more

Compliance into the Weeds-Episode 65-The Trouble with Non-GAAP Metrics

by Thomas Fox on

In this episode Matt Kelly and I take deep dive into the issue of non-GAAP metrics and its implications. We were inspired an article in this quarter's MIT Sloan Management Review entitled, "The Pitfalls of Non-GAAP Metrics"...more

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