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Common Scenarios Triggering False Claims Act Violations, Part 3: Claims and Investigations
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DE Under 3: OFCCP Changes Up Important Technical Details of its Audit Selection Process in First FY 2024 CSAL
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DE Under 3: US DOL Inspector General’s Office Plans to Review Effectiveness of OFCCP Compliance Evaluations
DE Under 3: What Federal Contractors Need to Know About OFCCP's New Audit Scheduling Letter
DE Under 3: What’s New in OFCCP’s Latest Audit Scheduling Letter for Supply & Service Contractors
Independent Audits of Nonprofit Organizations With Douglas Cook
DE Under 3: U.S. OPM Proposed Allowing Federal Managers To Avoid Most Qualified Candidates To Pick Those Who Offer Better “Fit”
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After ALJ: Options and Opportunities in the Face of an Unfavorable ALJ Decision
The Presumption of Innocence Podcast: Episode 21 - Conservation Easement Donations: Tax Shelter or Charitable Contribution Deduction?
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I Understood There Would Be No Math: Audits, Extrapolations, and a New Set of Rules
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Constangy Webinar - DEI Audits: Tools to Enhance Your DEI Practices
According to the Institute of Internal Auditors “Politics of Internal Auditing” (2015), 55% of chief audit executives were directed to commit important findings from their audit reports. 49% of chief audit executives were...more
The following newsletter provides a roundup summarizing enforcement actions, guidance, rulemakings, and other public statements taken by a federal and/or state financial services regulatory agency, specifically focusing on:...more
On February 9, 2022, the U.S. Securities and Exchange Commission (the “SEC”) proposed new rules and amendments under the Investment Advisers Act of 1940 (the “Advisers Act”) to augment the regulation of private fund advisers....more
BROKER-DEALER - FINRA Releases New Targeted Exam Letter Regarding Order Routing Conflicts - On November 10, the Financial Industry Regulatory Authority released the contents of a new Order Routing Conflicts targeted...more
Federal District Court Approves Flash Crash Spoofer’s US $38 Million Settlement; Federal Appeals Court Appears Sympathetic to Michael Coscia’s Claim That Spoofing Prohibition Is Too Vague - The US federal court handling...more
Summary of private equity firms’ compliance obligations, discussion of notable developments in 2015 and outlook for 2016. US federal laws and regulations, as well as the rules of self-regulatory organizations (SROs),...more
During the holiday period the SEC filed three insider trading cases as administrative proceeding. Three actions were brought involving major Wall Street banks; one centered on “parking” allegations involving Morgan Stanley...more
The SEC prevailed in one court case this week but lost in another. In an investment fund fraud action the agency won at trial. In the First Circuit, however, it lost in an appeal of the long running action against two former...more
The Yates Memo, refocusing DOJ criminal and civil corporate investigations, continues to be the critical topic of discussion this week. The Memo, discussed here, directs that individuals be the focus of the inquiry from the...more
In a burst of post-Labor Day energy, the SEC filed a number of significant actions. Those include a series of actions arising out of the audit failure by BDO; actions centered on a financial fraud at an on-line lender; cases...more
CME Group Files Disciplinary Actions for Trading Ahead of Block Trades and Failure to Supervise an Employee Engaging in Disruptive Trading Activities - In two cases of first impression, CME Group exchanges brought and...more
The Commission resolved its actions against the PRC based affiliates of five major accounting firms for failure to produce audit work papers. The settlement contains a series of procedures designed to facilitate production in...more
Cybersecurity has increasingly become a critical issue for all types of businesses, few more so than broker-dealers, investment advisers and others in the financial sector. The cyber threat is much broader than customer data...more
In this issue: - SEC Requests Comment on FINRA Rules - CFTC Issues Interpretation Regarding Auditor Independence Standards - OTC Derivatives Regulators Group Issues Report to G20 - NFA...more
In this issue: - NASDAQ Launches Marketplace for Private Companies - SEC Proposes Rules to Enhance Oversight of Clearing Agencies - FINRA Proposes to Amend Rules 2210 and 2214 - CME Group Exchanges...more
- Regulatory Updates: CFTC Adopts “Substituted Compliance” Approach for Registered Investment Companies that are Commodity Pools; SEC’s Final Rules on General Solicitation and Bad Actor Disqualification for Investment...more
In this issue: - NASDAQ Proposes Internal Audit Function Requirement for Listed Issuers - FINRA’s Frequently Asked Questions on Electronic Blue Sheet Submissions Updated Regarding Order Execution Time -...more