Corruption, Crime & Compliance - Episode 208 - A Deep Dive into the WPP FCPA SEC Settlement
FCPA Compliance and Ethics Report-Episode 122-with Matt Kelly on Alstom, Avon and Petrobras
FCPA Compliance and Ethics Report-Episode 118-the Alstom FCPA Enforcement Action
FCPA Compliance and Ethics Report-Episode 88, Internal Controls for Third Parties Under the FCPA, Part I
The SEC continues to expand its cybersecurity enforcement authority to include allegations that a company's failure to monitor its managed security service providers (MSSP) amounts to violations of federal securities laws....more
The Nutter Securities Enforcement Update is a periodic summary of noteworthy recent securities enforcement activity, settlements, decisions, and charges. ...more
In this episode, Michael Volkov reviews the WPP SEC FCPA settlement. WPP, the Largest Global Advertising Group, Settles FCPA Charges with SEC for $19.2 Million. After a long hiatus, the SEC announced a settlement with WPP...more
The SEC’s FCPA enforcement action against WPP presents a number of important lessons learned, ranging from third-party risk management, properly responding to employee complaints and red flags, and failure to integrate...more
On October 15, 2020, the US Securities and Exchange Commission (SEC) issued a cease and desist order (Order), settling charges against a registrant for controls violations relating to a stock buyback plan implemented during...more
We previously discussed an SEC enforcement action against Andeavor LLC for controls violations relating to a stock buyback plan it implemented while it was in discussion to be acquired by Marathon Petroleum Corp. in 2018....more
In July 2020, a publicly traded pharmaceutical company entered into a settlement with the Securities and Exchange Commission, without admitting or denying findings, and agreed to pay a financial penalty relating to various...more
Compliance professionals, we need to talk about accounting controls again. They’re back in the news these days as an important part of FCPA compliance. In fairness, accounting controls have never stopped being an...more
• A payment to a government official can take many forms. • The SEC charges bank for books and records violation even absent a bribery charge. • Industry-wide enforcement is a continuing tactic for U.S. regulators. ...more
The big one finally is resolved. The long-awaited Walmart Inc. (Walmart) Foreign Corrupt Practices Act (FCPA) enforcement action was announced yesterday. This massive case came in with multiple documents, a long list of...more
After a long silence since guidance was last issued a year ago, there’s now widespread expectation that the Securities and Exchange Commission will get much more specific this year about new cybersecurity disclosures for...more
On Oct. 16, 2018, the Securities and Exchange Commission (the “SEC”) released a cautionary report discussing whether certain public companies that had become victims of cyber-related fraud may have violated federal securities...more
On October 16, 2018, the SEC issued a 21(a) report announcing that it had investigated whether certain public companies that were victims of oftentimes unsophisticated, cyber-related frauds had violated federal securities...more
On October 16, 2018, the SEC released an Investigative Report detailing recent email spoofing schemes that caused nine public companies to lose a total of nearly $100 million. Building on its February 2018 guidance about the...more
• The SEC issued guidance in the form of a rare “21(a) report” this week after investigating a series of email frauds impacting 9 unnamed companies. • These email-based frauds, referred to as “CEO scams” or “vendor scams,”...more
King’s back story of starting with the great psychedelic band Strawberry Alarm Clock and then moving to the Southern rockers Lynyrd Skynyrd, informs today’s blog post on the Legg Mason, Inc. (LM) Securities and Exchange...more
Yesterday the Securities and Exchange Commission (SEC) resolved a Foreign Corrupt Practices Act (FCPA) enforcement action involving Kinross Gold Corporation (Kinross). ...more
No one needs to be reminded about the importance of anti-corruption compliance. For global companies, anti-corruption risks are amongst the top 3 risks identified by corporate leaders....more
A most “daring act” seems to be a good way to introduce a multi-part look at the recent Foreign Corrupt Practices Act (FCPA) enforcement action involving the Chilean chemicals and mining company Sociedad Química y Minera de...more
The Embraer FCPA settlement action contains a number of important lessons learned and compliance reminders. In several significant respects, the Embraer case confirms in several areas why proactive compliance programs are...more
The SEC filed another action centered on a restatement resulting from improper accounting and internal controls. In this instance the firm lacked procedures for dealing with related party transactions despite contrary...more
This Annual Review (“Review”) was prepared by the Subcommittee on Annual Review of the Committee on Federal Regulation of Securities of the ABA Business Law Section. The Review covers significant developments in federal...more
In a wide-ranging speech on Tuesday, Securities and Exchange Commission Director of Enforcement Andrew Ceresney discussed recent SEC actions and current concerns involving the pharmaceutical and medical technology industries....more
Porphyry is a type of stone that was much favored in the Roman world. In a review of several books in the New York Review of Books, entitled “The Purple Stone of Emperors”, Peter Brown looked into the history of the lithic in...more
Following on the heels of a case, discussed in this post, in which a CEO and CFO were charged with internal control and books and records violations (but no typical financial statement fraud allegation), comes another case...more