The Legal Tightrope: Surviving Parallel Investigations
Navigating Government Contracts: Diana Shaw on Oversight and Whistleblower Protections
The Presumption of Innocence Podcast: Episode 45 - The Grit, Grace and Gift of Second Chances
The Justice Insiders Podcast - The Ever-Expanding Net: Corporate Compliance in an Era of Increasing Trade Sanctions and Restrictions
False Claims Act Insights - Are All Healthcare “Kickbacks” Subject to FCA Liability?
Episode 333 -- The Boeing Proposed Plea Agreement
DOJ’s New Self-Disclosure Policy and Corporate Whistleblower Awards Pilot Program
False Claims Act Insights - Assessing the Fallout from a Thermonuclear FCA Verdict
FCPA Survival Guide - Step 8 - Investing in Compliance
Exploring the AI and Crypto Intersection
The Justice Insiders Podcast: Jarkesy’s Implications for the Administrative State
The Presumption of Innocence Podcast: Episode 41 - The Dynamics of Decision-Making: Psychology and the Criminal Justice System
INTERPOL and Child Kidnapping Cases. What are INTERPOL’s Abilities and Limitations?
False Claims Act Insights - Eureka! Government Investigators Seek Out Research Misconduct
The Justice Insiders Podcast - AI-Washing: Everything Old Is New Again
The CFPB and State AGs Act Jointly Against Online Educational Company
Will the U.S. Have a GDPR? With Rachael Ormiston of Osano
Episode 328 -- Sanctions Enforcement Risks and Redlines
FCPA Survival Guide: Step 3 - Extensive Remediation
Episode 324 -- Third-Party Risks and Sanctions Compliance
In the world of compliance and ethics, the Citigroup internal control debacle serves as a glaring reminder of the critical importance of robust, well-designed, functioning and effective internal controls. The U.K. Financial...more
Compliance Today (January 2021) - Just a few months before Jane Fraser takes over as chief executive officer—the first woman to run a major Wall Street bank —Citigroup agreed to pay $400 million to settle an Office of the...more
Federal authorities are prepping to “reprimand Citigroup Inc. for failing to improve its risk-management systems—an expansive set of technology and procedures designed to detect problematic transactions, risky trades and...more
Here’s all you need to know from the Fed minutes released yesterday, including next month’s rate increase, an apparent plan to continue rate hikes at their gradual pace (unless White House trade policies “scramble their...more
The CFTC’s reportedly investigating the interest rate swap activities of Citigroup and others. Swaps allow companies to “hedge against a rise or fall in interest rates on the debt that they issue or hold, with banks usually...more
Michael Coscia Sentenced to Three Years’ Imprisonment for Spoofing and Commodity Fraud: Michael Coscia, the first person prosecuted and convicted under a law prohibiting spoofing that was enacted after the 2007-2008...more
On Tuesday, the SEC announced that Citigroup would pay $7 million and admit that it submitted “inaccurate trade data” to the Commission over a period of 15 years in order to resolve claims that it left out “thousands of...more
No Dog Days of August for the SEC—A Recap of a Busy Month - Why it matters: Who says there is a government slowdown in August? Not for the SEC. August 2015 turned out to be very busy indeed for the agency, which...more
Yesterday the Securities and Exchange Commission (SEC) announced a resolution with Bank of New York Mellon Corporation (BNY Mellon) for violations of the Foreign Corrupt Practices Act (FCPA). This was the first enforcement...more
The market crisis may have ended years ago, but not the SEC’s supply of cases from that time period. The agency filed a settled action in which those soliciting sophisticated investors misrepresented the risks of two funds,...more
CFTC Issues CME Group Report Card: Scores Generally Good But NYMEX and COMEX Directed to Continue to Enhance Spoofing Surveillance - The Chicago Mercantile Exchange Group found early presents under its Christmas tree...more
Appeals for the Second Circuit has vacated a provocative order by Southern District of New York Judge Jed Rakoff. In the November 2011 order, Rakoff rejected a proposed "no-admit, no-deny" consent decree to resolve an SEC...more
In the roll-up to the Labor Day weekend, the SEC issued new rules regarding asset backed securities and credit rating agencies. The Commission also announced a new pilot program on tick size....more
On remand following a Second Circuit decision vacating his June 2011 rejection of a settlement between Citigroup and the SEC, Judge Jed Rakoff of the Southern District of New York approved the settlement, finding that it met...more
Fed Issues Report on the Economic Well-Being of U.S. Households - On August 7, the Fed provided a snapshot of the self-perceived financial and economic well-being of U.S. households and the issues they face, based on...more
To settle charges related to the packaging, marketing, sale, and issuance of residential mortgage-backed securities (RMBS), Citigroup will pay a total of $7 billion, including a record $4 billion fine to the Department of...more
The Commission continued to focus on the markets this week, brining another action involving the operation of a partially dark pool. The ECN operator was a subsidiary of Citigroup. The SEC alleged that confidential customer...more
In a closely-watched decision involving judicial review of agency settlements, the Unites States Court of Appeals for the Second Circuit vacated United States District Court Judge Jed Rakoff’s 2011 order rejecting a proposed...more
In an eagerly anticipated decision, the U.S. Court of Appeals for the Second Circuit vacated the 2011 decision of Judge Jed S. Rakoff of the U.S. District Court for the Southern District of New York, rejecting a proposed...more
In November 2011, Judge Jed Rakoff of the Southern District of New York ignited a firestorm of commentary and concern among the securities bar by declining to approve a settlement between the SEC and Citigroup in which the...more
On June 4, 2014, the United States Court of Appeals for the Second Circuit vacated and remanded a November 28, 2011 order from the United States District Court for the Southern District of New York refusing to approve a...more
On June 4, 2014, a three-judge Second Circuit panel reversed and remanded Judge Rakoff’s 2011 order that rejected an S.E.C. settlement with Citigroup. The proposed settlement resolved the S.E.C.’s securities fraud case...more
Wednesday’s decision by the U.S. Court of Appeals for the Second Circuit in the Citigroup case is significant because it clarifies the standards for judicial review of consent decrees in SEC enforcement proceedings and...more
The SEC had mixed results in court this week. A Manhattan jury returned a verdict against the agency in a high profile and long-running insider trading case where the agency had previously obtained favorable rulings from the...more
I recently wrote about Judge Rakoff’s refusal to enter the SEC’s proposed consent decree in SEC v. Citigroup Global Markets, Inc., 827 F. Supp. 2d 328 (SDNY 2011) – and the shift in SEC enforcement policy that it prompted. ...more