Compliance Week published its 2014 Anti-Bribery and Corruption Benchmarking Report, a survey of over 180 executives involved in ethics and FCPA compliance and internal audit. The Survey focused on risk, dealing with third...more
7/1/2014
/ Audits ,
Bid Rigging ,
Bribery ,
Chief Compliance Officers ,
Compliance ,
Cybersecurity ,
Due Diligence ,
Foreign Corrupt Practices Act (FCPA) ,
Money Laundering ,
Price-Fixing ,
Privacy Laws ,
Third-Party ,
Third-Party Risk
High speed trading and conflict of interest in the market place were the topics of the week. Two Senate committees held hearings on the issues which were the focus of the Michael Lewis book Flash Boys and its claim that the...more
The U.K.’s Serious Frauds Office prevailed in its first overseas corruption trial, securing a jury verdict in its favor and against two former Innospec executives. The case stems from a referral by the DOJ following FCPA...more
In a holiday shortened week, the SEC filed actions based on the malfeasance at a transfer agent, financial fraud, insider trading and investment fund fraud. The action involving the transfer agent stems from an inspection and...more
Since the announcement of the Financial Fraud Task Force and the Center for Risk and Quantitative Analytics last year many have expected an uptick in the number of financial fraud actions. While those actions were once a key...more
A now retired Deloitte & Touche LLP partner settled charges that he violated the auditor independence rules, engaged in improper professional conduct and caused a firm audit client to violate Exchange Act Section 13(a). The...more
The Commission got split decisions in court this week. It prevailed in one high profile trial, obtaining a jury verdict in its favor. It lost a significant summary judgment motion regarding the statute of limitations...more
The SEC won a significant courtroom verdict Monday when a jury in New York returned a verdict in favor of the agency in the complex, high profile trading action brought almost four years ago against Samuel Wyly and the estate...more
Welcome to Dorsey & Whitney’s monthly Anti-Corruption Digest. Anti-corruption enforcement crosses boundaries like no other, so keeping up to date is more important than ever. In this digest, we draw together news of...more
Welcome to Dorsey & Whitney’s monthly Anti-Corruption Digest. Anti-corruption enforcement crosses boundaries like no other, so keeping up to date is more important than ever. In this digest, we draw together news of...more
The number of FCPA enforcement actions brought in recent years has declined. The SEC, for example, reports that in fiscal 2013 it brought 8 cases, compared to 10 in 2012 and 15 in 2011. Nevertheless, those who might be...more
2/11/2014
/ Anti-Corruption ,
Chief Compliance Officers ,
Compliance ,
Corporate Counsel ,
Corporate Culture ,
Corruption Perceptions Index ,
Department of Justice (DOJ) ,
Enforcement ,
Foreign Corrupt Practices Act (FCPA) ,
Fraud ,
Risk Assessment ,
Risk Mitigation ,
Securities and Exchange Commission (SEC) ,
UK Bribery Act
SEC Chair Mary Jo White outlined the 2014 agenda for the SEC in recent remarks. SEC Chair Mary Jo White, 41st Annual Securities Regulation Institute, Coronado, California (Jan. 27, 2014)(here). Portions of the agenda focused...more
The Commission, as part of its retooled enforcement program, is, in part, focusing on gatekeepers such as attorneys and accounts in an effort to achieve omnipresence. This has resulted in a number of proceedings against...more
The high profile insider trading trial of Matthew Martoma moved forward in New York this week with testimony on behalf of the prosecution. The SEC and four other agencies joined in granting relief from a provision of the...more
1/17/2014
/ Bank Holding Company Act ,
Banks ,
Collateralized Debt Obligations ,
Compliance ,
Criminal Prosecution ,
Dodd-Frank ,
Enforcement Actions ,
Insider Trading ,
Securities and Exchange Commission (SEC) ,
Securities Exchange Act ,
Trust Preferred Securities ,
Volcker Rule
The SEC National Examination Program announced its 2012 examination priorities. Those priorities are selected by senior staff from the National Exam Program’s offices along with senior SEC staff from the various Divisions and...more
The insider trading trial of former SAC Capital official Matthew Martoma opened this week in Manhattan with jury selection. The SEC announced the resignation of George Canellos, Co-director of the Division of Enforcement....more
1/10/2014
/ Anti-Money Laundering ,
Australia ,
Banking Sector ,
Bernie Madoff ,
CFTC ,
Compliance ,
Deferred Prosecution Agreements ,
Department of Justice (DOJ) ,
Enforcement ,
FERC ,
Financial Industry Regulatory Authority (FINRA) ,
Financial Statements ,
Foreign Corrupt Practices Act (FCPA) ,
Fraud ,
George Canellos ,
Hong Kong ,
Insider Trading ,
Investment Funds ,
JPMorgan Chase ,
Libor ,
Martoma ,
Money Laundering ,
Ponzi Scheme ,
RBS ,
SAC Capital ,
Securities ,
Securities and Exchange Commission (SEC) ,
Securities Fraud ,
Securities Litigation ,
Short Sales ,
Suspicious Activity Reports (SARs) ,
UK
Parts I and II of this series looked back at 2013 and examined select cases which may influence the future path of SEC enforcement. This segment focuses on the path being charted for the Enforcement Division by a new...more
PRC based issuers, and the reliability of the financial information for these companies, continued to be a key issue for the Commission as well as the PCAOB in 2013. An action brought by the Commission against Subaye, Inc....more
SEC Enforcement is in transition. The agency has a new Chair, new Commissioners and a new Director of the Division of Enforcement. Aggressive new approaches have been outlined, building on the notion that the enforcement...more