California Doctor to Pay $3 Million for Insider Trading - On December 18, a California oncologist agreed to pay the US Securities and Exchange Commission (SEC) $3 million to resolve allegations of insider trading. The SEC...more
In 2012 and 2013, while James Snyder was the mayor of Portage, Indiana, the city purchased garbage trucks from local trucking company Great Lakes Peterbilt for roughly $1.1 million....more
In Snyder v. United States, the Supreme Court of the United States could redefine the legal boundaries regarding federal bribery as it prepares to answer whether the primary federal bribery statute, 18 U.S.C. § 666,...more
Earlier this week, the Southern District of New York dismissed bribery and honest services wire fraud charges brought against New York’s former lieutenant governor, Brian Benjamin, based upon the Indictment’s failure to...more
• A payment to a government official can take many forms. • The SEC charges bank for books and records violation even absent a bribery charge. • Industry-wide enforcement is a continuing tactic for U.S. regulators. ...more
Today, I conclude my short exploration of the recent spate of Foreign Corrupt Practices Act (FCPA) enforcement actions brought by the Securities and Exchange Commission (SEC) at the close of its fiscal year. Each FCPA...more
The bribery provisions of Exchange Act Section 30A are one of the three critical components of the Foreign Corrupt Practices Act. The other two are the books and records and the internal control requirements....more
My good friend and colleague, Tom Fox, has written an interesting post on the SEC’s recent United Airlines settlement for $2.4 million for domestic bribery. As Tom has noted, the interesting aspect of the SEC’s enforcement...more
In a settlement highlighting the need for public companies to implement – and adhere to – effective internal controls, United Airlines “United” recently paid a $2.4 million civil penalty to the Securities and Exchange...more
Earlier this week a most interesting non-Foreign Corrupt Practices Act (FCPA) bribery and corruption enforcement, actions was announced by the Securities and Exchange Commission (SEC). It involved a clear quid pro quo benefit...more
Yesterday on the podcast, the FCPA Compliance and Ethics Report, I posted the full oral argument from the Supreme Court in the case of McDonnell v. US (shout out to Web Hull for sending it to me), which is the appeal of the...more