News & Analysis as of

Books & Records Compliance Cease and Desist Orders

Seward & Kissel LLP

SEC Settles Charges with Nine Advisers in Marketing Rule Sweep

Seward & Kissel LLP on

Who may be interested: Investment Advisers. Quick Take: The SEC recently settled charges with nine investment advisers related to their use of hypothetical performance information on their websites without adopting or...more

Thomas Fox - Compliance Evangelist

Recidivist Eni: Corruption, Controls and Books and Records

Eni S.p.A (Eni) joined the two-time Foreign Corrupt Practices Act (FCPA) loser ranks last week when it agreed to a Cease and Desist Order (Order) with the Securities and Exchange Commission (SEC) for violations of the...more

Thomas Fox - Compliance Evangelist

Two Tickets to Paradise and the Thiruvengadam FCPA Settlement

We got a fair bit more clarity on the Cognizant Technologies Solutions Corporation (“Cognizant”) Foreign Corrupt Practices Act (FCPA) last week, when Sridhar Thiruvengadam, the Chief Operating Officer (COO) agreed to settle...more

Thomas Fox - Compliance Evangelist

A ‘Most Daring Act’ and the SQM FCPA Enforcement Action – Part I

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

Thomas Fox - Compliance Evangelist

A Company Must Do Compliance – The Mondelez FCPA Enforcement Action

In almost every Foreign Corrupt Practices Act (FCPA) enforcement action, there are nuggets to be gleaned for any Chief Compliance Officer (CCO) or compliance practitioner. All one has to do is look for them. Back in 2012,...more

Thomas Fox - Compliance Evangelist

John Fogarty Rocks-Nu Skin Informs Oversight

I recently saw John Fogerty in concert. For those you are not aware, he was a founding member and the driving force behind Creedence Clearwater Revival (CCR), one of the very top American groups from the 1960s and early...more

Orrick, Herrington & Sutcliffe LLP

This Cold Bud Is For You: SEC Sanctions Anheuser-Busch for “Chilling” Employee from Communicating with SEC

On September 28, 2016, the SEC announced that Anheuser-Busch agreed to pay $6 million to settle charges of Foreign Corrupt Practices Act and Dodd-Frank whistleblower violations. The SEC’s order stated that AB InBev violated...more

Thomas Fox - Compliance Evangelist

Anheuser-Busch InBev and Lessons in Joint Venture FCPA Compliance

Just in time for National Beveridge Day comes the Foreign Corrupt Practices Act (FCPA) enforcement action involving Anheuser-Busch InBev (ABI), where the company paid $6 million to settle charges that it violated the FCPA and...more

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