News & Analysis as of

Deutsche Bank Recidivism

Thomas Fox - Compliance Evangelist

Compliance Program Lessons from a Recidivist

Recidivist behavior is something that the US government is forced to face in Foreign Corrupt Practices Act (FCPA) enforcement from time-to-time. When a company agrees to a Deferred Prosecution Agreement (DPA) or...more

Dorsey & Whitney LLP

WKSI Waivers For A Recidivist – And a Dissent By Commissioner Stein

Dorsey & Whitney LLP on

The question of waivers from certain disqualifications under the securities laws which are triggered automatically in certain instances — such as on the entry of a guilty plea — continues to be a controversial topic at the...more

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