Transaction Monitoring Under the FCPA
The Nutter Securities Enforcement Update is a periodic update of noteworthy recent securities enforcement activity, settlements, decisions, and charges. We provide brief summaries that highlight recent enforcement action...more
Goldman Sachs is reportedly in negotiations with federal prosecutors to resolve claims about its role in the Malaysian 1MDB scandal for upwards of $2 billion. A settlement—which “could include a guilty plea from Goldman’s...more
According to a memo circulating amongst Republican-party leaders as of February 13th, Republicans in the House of Representatives are planning to propose a significant curtailment of the U.S. Securities and Exchange...more
Yesterday the Securities and Exchange Commission (SEC) announced a resolution with Bank of New York Mellon Corporation (BNY Mellon) for violations of the Foreign Corrupt Practices Act (FCPA). This was the first enforcement...more
Meatloaf’s standard Paradise by the Dashboard Light, is the lead in for today’s blog post (the ‘automotive’ focus of the song and not the ‘paradise’ focus for the less prurient among you.) I still think that one of the most...more
After the Department of Justice announced its declination of the Morgan Stanley case, the FCPA Paparazzi littered the Internet with recommendations of steps to take modeled on Morgan Stanley’s compliance program. Companies...more
The goal of any company regarding its compliance regime should be to make compliance a part of the fabric of your company and the face that you present to the world. That was the message from the interview conducted by Adam...more
Transaction monitoring was mentioned in a couple of significant enforcement actions of 2012. I think that it will move to becoming a best practice in FCPA compliance programs. This video will explain how transaction...more
As we welcome in 2013, it is appropriate to reflect back on some of the things which have occurred over 2012 and in the Foreign Corrupt Practices Act (FCPA) enforcement world, it was quite a significant year. The Department...more