News & Analysis as of

Fines Internal Controls

Thomas Fox - Compliance Evangelist

Internal Controls and Humans in the Loop: Lessons from Citigroup’s $126 Million Mistake

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

Hanzo

Financial Data Compliance and Enterprise Information Archiving

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When it comes to making sure financial data is safe and meets compliance regulations, understanding the different regulatory bodies and how they affect your organization is a vital first step. Two of the most common...more

Goodwin

Four Lessons from Two FINRA Enforcement Actions against Crowdfunding Portals

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On May 4, 2022, FINRA announced that it had fined two FINRA-registered funding portals a combined $1.75 million for failing to comply with securities laws and rules designed to protect crowdfunding investors. Funding portals...more

Kaufman & Canoles

Credit Union Client Alert – Wells Fargo Must Pay $250 Million Fine

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The Office of the Comptroller of the Currency (OCC) issued a $250 million civil penalty against Wells Fargo Bank, NA for flaws in the bank’s home loan loss mitigation program. In addition, the OCC issued a cease-and-desist...more

Bracewell LLP

SEC Gets Cyber-Serious About Disclosures

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As cyberattacks continue to attract greater attention, the SEC has taken an additional step in its efforts to bring enforcement actions related to cyber disclosures. On June 14, the SEC announced settled charges against a...more

Thomas Fox - Compliance Evangelist

HorrorFest 2020 Celebration: The Revenge of Frankenstein and the J&F FCPA Resolution

In this third edition of October HorrorFest 2020 celebration we consider the first Hammer film sequel (and second in the series) – The Revenge of Frankenstein which was released in 1958. It begins as the Curse of Frankenstein...more

Pillsbury Winthrop Shaw Pittman LLP

Registration and Compliance Obligations are Reality for Private Funds in the Cayman Islands

New law imposes registration and compliance obligations on private funds that carry on business in or from the Cayman Islands. Absent an exemption, all private funds that carry on business in or from the Cayman Islands will...more

Skadden, Arps, Slate, Meagher & Flom LLP

Ericsson Agrees To Pay Over USD $1 Billion To Settle FCPA Charges

On December 6, 2019, Telefonaktiebolaget LM Ericsson (Ericsson or the Company), resolved long-running investigations by the U.S. Department of Justice (DOJ) and the U.S. Securities and Exchange Commission (SEC) into the...more

Mitratech Holdings, Inc

Global Voices: Compliance Lessons Global Organisations Can Learn From Never-Ending Regulatory Fines

With corporate compliance and ethics now escalating to be a boardroom concern, and discussions around how to make organisations behave better are happening at the highest levels, what compliance lessons can all organisations...more

Broker-Dealer Compliance + Regulation

First State Charges Broker-Dealer in Connection with Violations of DOL Fiduciary Rule

On February 15, 2018, the Enforcement Section of the Massachusetts Securities Division (the “Division”) of the Office of the Secretary of the Commonwealth charged a registered broker-dealer (the “Broker-Dealer”) that operated...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

Rolls-Royce Global Enforcement Action: Part I

When most people across the globe think of Rolls-Royce, one word comes to mind – excellence. Yet that image largely relates to Rolls-Royce Limited, the automobile manufacturer, which was founded in 1909. Just a few years...more

Thomas Fox - Compliance Evangelist

Embraer FCPA Enforcement Action – Part III

Today I continue my exploration of the recently announced Department of Justice (DOJ) and Securities and Exchange Commission (SEC) Foreign Corrupt Practices Act (FCPA) enforcement action with the announcement of the...more

Dorsey & Whitney LLP

Hong Kong Securities Laws Violations: SFC’s Case Against Moody’s – Part 2

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On March 31, 2016, the Securities and Futures Appeals Tribunal (“SFAT”) upheld the disciplinary action of the SFC against Moody’s. This landmark decision is the first of its kind, as a disciplinary action brought by the...more

Dechert LLP

SEC Imposes Penalties on Company and Officers for Inadequate Staffing in Accounting Department

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Highlights - The SEC settled charges against Magnum Hunter Resources Corporation and two of its officers for deficient oversight of the company’s internal controls over financial reporting, resulting in fines of...more

Dorsey & Whitney LLP

Can an Enforcement Standard be Discerned from the SFC’s Case Against Moody’s?

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The hearings have recently concluded in Moody’s appeal of the November 24, 2014 decision of Hong Kong Securities and Futures Commission (the “SFC”) to fine Moody’s HK$23 million for its release of a report applying a “red...more

McDermott Will & Emery

Focus on China - October 2015

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Welcome to the third issue of Focus on China Compliance for 2015. According to the FCPA Blog’s October 2015 Corporate Investigations List, China leads the countries reported to be involved in FCPA investigations with 29...more

Alston & Bird

DOJ Revises the FCPA Resource Guide

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In June 2015, the Department of Justice and the Securities and Exchange Commission (SEC) published revisions to their jointly issued A Resource Guide to the U.S. Foreign Corrupt Practices Act. The Resource Guide, initially...more

Mintz

Foreign Corrupt Practices Act (FCPA): Israel Beware – Trends in Enforcement.

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Intuitively, Israeli companies and their directors would likely assume that their businesses are immune to investigation and the assessment of penalties by US regulators that are separated by a vast ocean and located more...more

Dorsey & Whitney LLP

Barclays Is Sanctioned By The FCA and The SEC

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Barclays took a double hit from regulators yesterday. First the Financial Conduct Authority in the UK fined Barclays Bank Plc, about £38 million for putting £16.5 billion of client assets at risk. Then the SEC imposed a $15...more

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