News & Analysis as of

Securities and Exchange Commission (SEC) Due Diligence Compliance

J.S. Held

South of the Border Compliance: Enhancing Integrity & Risk Management in Latin American Operations

J.S. Held on

In February 2025, the Trump administration directed a significant shift in the US Department of Justice’s (DOJ) enforcement priorities by announcing a 180-day suspension of new actions under the Foreign Corrupt Practices Act...more

Lowenstein Sandler LLP

Key Considerations for Alternative Data and AI Vendors to Investment Firms: Demonstrating Compliance in the Face of an Evolving...

The Securities and Exchange Commission (SEC) has previously provided guidance through risk alerts, proposed rules, and enforcement actions that outline expectations for registered investment advisers and other financial firms...more

American Conference Institute (ACI)

[Event] Global Anti-Corruption, Ethics & Compliance - June 10th - 11th, New York, NY

ACI's Global Anti-Corruption, Ethics & Compliance – New York is your best opportunity to hear how companies are addressing the status of DOJ and SEC priorities, effective compliance and risk strategies, strengthening...more

Flaster Greenberg PC

SEC Offers Updated Guidance for Rule 506(c) Private Placements

Flaster Greenberg PC on

On March 12, 2025, the SEC published a No-Action Letter clarifying accredited investor verification requirements under Rule 506(c)....more

Guidepost Solutions LLC

How Corporations Can Protect Themselves by Conducting Supply Chain Due Diligence

In today’s complex global market, companies face significant risks when it comes to managing their supply chains. The recent criminal complaints against major tech firms like Apple, Dell, and Microsoft for allegedly using...more

ArentFox Schiff

FinCEN Releases Final Anti-Money Laundering Rule for Investment Advisers

ArentFox Schiff on

On August 28, the Financial Crimes Enforcement Network (FinCEN) issued a final rule establishing anti-money laundering and countering the financing of terrorism (AML/CFT) compliance obligations for US Securities and Exchange...more

Society of Corporate Compliance and Ethics...

[Virtual Event] ESG and Compliance Conference - November 7th, 8:00 am - 5:00 pm CT

Stay on top of ever-evolving ESG requirements and emerging trends - With the SEC’s newly issued rules surrounding ESG disclosures and the continued growth of regulations rolling out in the EU, Canada, Asia and elsewhere...more

Thomas Fox - Compliance Evangelist

Internal Reporting and Investigative Lessons from Star Trek: The Conscience of the King

Last month, I wrote a blog post on the tone at the top, exemplified in Star Trek’s Original Series episode, Devil in the Dark. Based on the response, some passionate Star Trek fans are out there. I decided to write a series...more

Guidepost Solutions LLC

Crypto Crackdown: 8 Key BSA/AML Fundamentals for FinTechs

In June 2024, multiple state regulators took joint action against Plutus Financial, Inc (Abra) ordering Abra to cease and desist certain operations in the U.S. and reimburse customers of virtual assets valued at $81.1 million...more

NAVEX

What a New SEC Enforcement Sweep Is Really Telling Us

NAVEX on

Attention all compliance officers at large technology companies – have you checked your mail lately? Because you might find a letter from the Securities and Exchange Commission with FCPA risk written all over it....more

Amundsen Davis LLC

Impact of the SEC’s 2024 Examination Priorities Report for Investment Advisers

Amundsen Davis LLC on

The Division of Enforcement (“Division”) for the Securities and Exchange Commission (“SEC”) released the 2024 Examination Priorities Report (“Report”) highlighting the key areas the Division will examine in 2024. The SEC’s...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

DOJ Official Cites Old West ‘WANTED’ Posters in Announcement of New Whistleblower Monetary Awards Program

On March 7, 2024, Deputy Attorney General Lisa Monaco said that the U.S. Department of Justice (DOJ) will test out a program to pay whistleblowers if they provide information on serious financial crimes and foreign and...more

American Conference Institute (ACI)

[Event] FCPA & Anti-Corruption for the Life Sciences Industry - May 9th - 10th, New York, NY

Hosted by the American Conference Institute, the 19th Annual FCPA & Anti-Corruption Conference for the Life Sciences Industry returns for another exciting year with carefully researched programming based on critical findings...more

J.S. Held

Crosscurrents—European Union Fails to Pass Corporate Sustainability Due Diligence Directive & SEC Bails on Scope 3 Requirements

J.S. Held on

Introduction - With the adoption by 196 parties of the Paris Agreement in December 2015, legally binding international climate change arrived. The Paris Agreement requires increasingly aggressive five-year cycles climate...more

Holland & Knight LLP

FinCEN Proposal Potentially Impacts Registered Investment, Exempt Reporting Advisers

Holland & Knight LLP on

The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) has issued a new notice of proposed rulemaking (NPRM), referred to herein as the "Proposed Rule," that would subject SEC-registered...more

ArentFox Schiff

How to Avoid an Independent Compliance Monitor: Lessons From the SAP Settlement

ArentFox Schiff on

This week, SAP SE (SAP), the German-based software company, agreed to pay over $200 million to resolve investigations by the US Department of Justice (DOJ) and US Securities and Exchange Commission (SEC) into violations of...more

ArentFox Schiff

What Does the New FEPA Legislation Mean for FCPA and Anti-Corruption Compliance Programs?

ArentFox Schiff on

On December 21 President Biden signed the Foreign Extortion Prevention Act (FEPA) as part of the Fiscal Year 2024 National Defense Authorization Act. The legislation addresses a perceived gap in the Foreign Corrupt Practices...more

American Conference Institute (ACI)

[Event] 40th International Conference on the FCPA - November 28th - 30th, National Harbor, MD

Hosted by American Conference Institute, the 40th International Conference on the FCPA returns for another exciting year with curated programming that shines a global spotlight on anti-corruption compliance challenges,...more

Woods Rogers

Real Estate Syndications: Legal Considerations for Syndicators (and Investors)

Woods Rogers on

Real estate syndication involves pooling funds from multiple investors to finance a real estate project. While syndication can be a profitable investment strategy, it also comes with various legal considerations and potential...more

HaystackID

Compliance Programs Under the FCPA: Ways to Minimize Liability for Payments to Foreign Officials

HaystackID on

Background Note: In their analysis of the Foreign Corrupt Practices Act (FCPA), Adam Rouse, Vazantha Meyers, and Ashish Prasad emphasize the crucial role of robust compliance programs in minimizing liability associated with...more

American Conference Institute (ACI)

[Event] 13th West Coast Forum on FCPA Enforcement and Compliance - June 14th - 15th, San Francisco, CA

Hosted by American Conference Institute, the 13th West Coast Forum on FCPA Enforcement and Compliance returns for another exciting year, providing the opportunity to connect with decision-makers from your industry, gather...more

Seward & Kissel LLP

SEC Staff Issue Risk Alert on Safeguarding Customer Records and Information at Branch Offices

Seward & Kissel LLP on

Who may be interested: Registered Investment Advisers, Broker-Dealers. Quick Take: The SEC’s Division of Examinations staff (Staff) recently issued a risk alert (Alert) highlighting deficiencies and trends that the Staff...more

The Volkov Law Group

Flutter Entertainment Settles SEC FCPA Case for $4 Million for Improper Payments to Russian Consultants

The Volkov Law Group on

Flutter Entertainment, the previous owner of PokerStars, agreed to pay the Securities and Exchange Commission $4 million for improper payments to Russian-based consultants, stemming from conduct committed by The Stars Group,...more

Guidepost Solutions LLC

Mergers + Acquisitions: 5 Tips For Navigating FCPA Risks

Among the risks inherent in a merger or an acquisition, few bring the financial and reputational consequences of the U.S. Foreign Corrupt Practices Act (“FCPA”). Background - The FCPA prohibits the offer, promise,...more

King & Spalding

SEC Proposes RIA Outsourcing Rule

King & Spalding on

On October 26, the SEC proposed a new Advisers Act rule (the “Proposed Rule”) that would establish specific obligations for Registered Investment Advisers with respect to outsourcing of “Covered Functions”, as that term is...more

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