News & Analysis as of

Chief Compliance Officers Cease and Desist Orders

Thomas Fox - Compliance Evangelist

WPP Enforcement Action: Part 3 – Investigative Failures

This week we are exploring the recent Securities and Exchange Commission (SEC) Cease and Desist Order (Order) entered into last week with WPP plc, the world’s largest advertising group, for paying bribes to Indian government...more

Foley & Lardner LLP

Foley Governance and Regulatory Alert: Dangers of Chief Compliance Officer Backdating Documents

Foley & Lardner LLP on

The Securities and Exchange Commission (“Commission” or “SEC”) recently instituted settled administrative and cease-and-desist proceedings against a chief compliance officer of a registered investment adviser for record...more

Thomas Fox - Compliance Evangelist

The Herbalife FCPA Enforcement Action: Part 4 – Final Thoughts

We are the end of my multi-part exploration of the Herbalife Nutrition Ltd (Herbalife) Foreign Corrupt Practices Act (FCPA) enforcement action with both the Department of Justice (DOJ) and Securities and Exchange Commission...more

Thomas Fox - Compliance Evangelist

Top SEC Enforcement Actions from 2019

Yesterday, I considered five Department of Justice (DOJ) Foreign Corrupt Practices Act (FCPA) enforcement actions. Today, I want to look at key FCPA enforcement actions by the Securities and Exchange Commission (SEC)....more

Thomas Fox - Compliance Evangelist

The NPA; The Petrobras FCPA Enforcement Action: Part III

This blog post concludes my multi-part exploration of the Petróleo Brasileiro S.A. – Petrobras (Petrobras) Foreign Corrupt Practices Act (FCPA) enforcement action. Today we consider the stunning result achieved by Petrobras –...more

McGuireWoods LLP

SEC Opens Cease-and-Desist Order Proceeding against Broker-Dealer and Chief Compliance / AML Officer

McGuireWoods LLP on

As we have highlighted in prior posts, regulators of financial institutions, including FinCEN, FINRA and SEC, have increasingly brought actions to bring organizations – and individuals – into compliance with AML / BSA...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

General Cable FCPA Enforcement Action – Part II: The Comeback

Yesterday I began an exploration of the General Cable Corporation (General Cable) Foreign Corrupt Practices Act (FCPA) enforcement action. It was settled with the DOJ via a Non-Prosecution Agreement (NPA) and the SEC via a...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

Foley & Lardner LLP

A Compilation of Enforcement and Non-Enforcement Actions

Foley & Lardner LLP on

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

Thomas Fox - Compliance Evangelist

Bristol-Myers Squibb FCPA Enforcement Action

Yesterday, the Securities and Exchange Commission (SEC) announced a Foreign Corrupt Practices Act (FCPA) enforcement action against Bristol-Myers Squibb Company (BMS) for the actions of the company’s joint venture (JV) in...more

Thomas Fox - Compliance Evangelist

BNY Mellon and Lessons Learned In Hiring Family Members – Part II

In yesterday’s post I reviewed the Securities and Exchange Commission (SEC) Foreign Corrupt Practices Act (FCPA) enforcement action involving the Bank of New York Mellon Corporation (BNY Mellon) around its hiring of sons and...more

Dechert LLP

SEC Issues Settled Enforcement Action Against Investment Adviser, its President and Senior Officers for Compliance Program...

Dechert LLP on

The U.S. Securities and Exchange Commission (SEC or Commission) issued a cease and desist order (Order) on June 23, 2015, against Pekin Singer Strauss Asset Management Inc. (Adviser), an investment adviser registered under...more

Thomas Fox - Compliance Evangelist

Economic Downturn Week, Part II – The Golden Gate Bridge and Employment Separation – Hotlines and Whistleblowers During Layoffs

I use the Golden Gate Bridge as an entrée to my continued discussion on the series on steps that you can use in your compliance program if you find yourself, your company or your industry in an economic downturn. Whether you...more

Thomas Fox - Compliance Evangelist

On the Oregon Trail: the BHP Enforcement Action and High-Risk Hospitality

The settlers who took off on this Great Emigration on the Oregon Trail did not have anything in the way of a road map. Fortunately for the modern day anti-corruption compliance practitioner, you do have road maps that can...more

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