FCPA

Commission seeks cooperation, promises transparency

Barriers to information may come in various forms, including data protection, privacy, confidentiality, bank secrecy, state secrecy, or national security laws. These laws, many of ...

A good day for a compliance examiner is helping a firm identify issues and working with that firm to correct those issues in an efficient, ...

The Commission’s enforcement program is not a television show with a season-end cliffhanger. So why are we all standing around talking about it as if ...

I think as you can see the Commission has at its disposal a wide variety of remedies and relief. And in the Division of ...

Bahn also took steps to circumvent Colliers’ then existing internal accounting controls by making false statements, fabricating documents, and creating multiple email accounts in order ...

The other shoe has now dropped in connection with Legg Mason’s involvement in a scheme dating back to 2004 to bribe Libyan government officials to ...

The Permal Employees, along with employees of Société Générale, also used coded language in furtherance of the scheme, including discussing when the Libyan Intermediary had ...

Because many of Credit Suisse’s clients were state-owned entities (“SOEs”), and because the individuals personally requesting employment or internships for their relatives and friends were ...

In the wake of the landmark Kokesh v. SEC decision, the Commission’s Enforcement division will redouble its efforts to bring cases as swiftly as possible, ...