Podcast: Common Risks and Challenges in Running a Global Ethics & Compliance Program
In this month's In Compliance Round-Up, we cover the following topics: Supreme Court Holds Federal Anti-Corruption Law Prohibits State and Local Officials from Accepting Bribes, But Not Gratuities - Ethics Guidance Issued...more
The Ethics & Compliance Initiative (ECI) recently released its 2023 Global Business Ethics Survey (GBES), which revealed some very concerning findings. For ethics and compliance officers globally, the findings highlight...more
Casey Kaplan, a K&L Gates alum, is the head of compliance at Nike where he currently serves as the senior legal director of global ethics and compliance. In this episode of Client Conversations With Craig Budner, Casey and...more
On December 14, 2022, the Securities and Exchange Commission (SEC) adopted several amendments and new disclosure requirements to address what it viewed as potentially abusive practices associated with Rule 10b5-1 plans,...more
The Office of Inspector General of the US Department of Health and Human Services (OIG) issued Advisory Opinion 22-14 (AO 22-14) on June 29, 2022, concerning continuing education (CE) programs to be offered by an...more
On May 25, 2022, the Securities and Exchange Commission (the “SEC”) introduced a proposal to amend certain rules and forms under the U.S. Investment Advisers Act of 1940 (the “Advisers Act”) to require investment advisers and...more
This special inaugural issue of McDermott’s Healthcare Regulatory Check-Up highlights noticeable enforcement activity, OIG regulatory developments, CMS regulatory developments and other key developments for healthcare...more
On April 26, 2022, the SEC’s Division of Examinations (“EXAMS”) issued a risk alert flagging certain notable deficiencies that it has observed related to advisers’ potential misuse of material non-public information (MNPI) in...more
The U.S. Department of Justice’s Antitrust Division launched a multi-agency law enforcement effort in November 2019 to combat fraudulent and anticompetitive schemes aimed at government procurement, grant and program funding....more
The Securities and Exchange Commission’s Office of Compliance Inspections and Examinations (OCIE) issued a risk alert entitled Observations from Examinations of Investment Advisers Managing Private Funds (the “Alert”). The...more
On March 23, the SEC Division of Enforcement (Enforcement) issued a public statement bluntly warning issuers and insiders connected to them, along with broker-dealers and investment advisers, about the unique risks of insider...more
Report on Research Compliance 17, no. 2 (January 23, 2020) - - More than two years after Ozgur Tataroglu’s paper was retracted, the HHS Office of Research Integrity found that it and two grant applications contained...more
SEC Proposes to Update Accredited Investor Definition to Increase Access to Investments - On December 18, 2019, the Securities and Exchange Commission (SEC) proposed amendments to the definition of “accredited investor” in...more
In 2019, Rx IP Update reported on a number of developments in Canadian life sciences IP and regulatory law. We review top developments below: 1) PMPRB: Amendments to Regulations will come into force July 1, 2020, court...more
Innovative Medicines Canada (IMC) has announced changes to its Code of Ethical Practices for the first time since the last significant update in 2014. IMC has indicated that several major changes have been made which include...more
The Securities and Exchange Commission’s Office of Compliance Inspections and Examinations on November 7, 2019 issued a Risk Alert in which the OCIE staff (Staff) discussed “the most often cited deficiencies and weaknesses”...more
In a Risk Alert dated November 7, 2019, the SEC’s Office of Compliance Inspections and Examinations reminded investment company advisers and boards that examiners are looking carefully at how firms approach and document the...more
I may be a little old-school on this, but I still like to pick weeds in the yard. It's good exercise, makes the yard look nicer, and gives my brain a little down time. There's a particularly pernicious type of weed in our...more
On May 9, 2019, Telefônica Brasil agreed to pay a US$4.13 million civil fine to settle U.S. Securities and Exchange Commission charges for violations of the internal accounting controls and recordkeeping provisions of the...more
As any medical product business knows, compliance with the AdvaMed Code of Ethics (the “Code”) is essential. While the Code is voluntary, many states require medical product manufacturers and companies to adopt compliance...more
On January 7, 2019, the New York State Department of Financial Services (DFS or the “Department”) issued guidance regarding internal whistleblowing programs, calling a “robust” whistleblowing program an “essential component...more
Only one month after releasing its exam priorities for this year, on February 7, 2017, the Securities and Exchange Commission (SEC) Office of Compliance Inspections and Examinations (OCIE) published a Risk Alert describing...more
In a new Risk Alert, OCIE’s National Exam Program provided investment advisers with insight into the five compliance topics most frequently identified in its exam deficiency letters. Registered investment advisers should...more
In Retail Wholesale & Department Store Union Local 338 Retirement Fund v. Hewlett-Packard Co., 2017 U.S. App. LEXIS 955 (9th Cir. Jan. 19, 2017), the United States Court of Appeals for the Ninth Circuit addressed for the...more