In Congressional hearings over the past two years, DOJ
officials have faced repeated questioning about the lack of FCPA prosecutions
against individuals. While the DOJ and the SEC have negotiated FCPA settlements
involving huge payments by the likes...
The SEC brought a fraud action against a company and its
Chairman and President for defrauding company shareholders out of more than
$110 million in the sale of their shares to the company by paying prices which
were as much as 300% under value. The...
Does the SEC need authority to impose larger civil
penalties? SEC Chairman Mary Schapiro recently told Congress the agency needs
additional authority to impose large fines. The story broke in the press the
day Judge Rakoff issued his order rejecting...
I write regularly about compliance convergence. One of
the areas which converge with anti-corruption compliance is export control.
Within the area of export control, a sub-area which is little discussed and
less understood, is the area of deemed exports...
The collapse of MF Global was a key topic on Capital Hill
this week. Lawmakers heard testimony from the former chairman of the firm as
well as FINRA. In other congressional hearings the SEC Enforcement Director
told a committee that members of congress...
Insider trading is a key enforcement priority for the SEC
and the DOJ. Now however it has become a populist issue centered on members of Congress. There have been repeated reports of Congressional members raking in
huge profits by using information...
The SEC continues to be aggressive in brining insider
trading cases, filing its latest action on "information and belief" and
"suspicious trading." SEC v. All Know Holdings Ltd., Case No. 11 cv 8605
(N.D. Ill. Filed Dec. 5, 2011...