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Thomas Fox
A Corporate Self-Compliance Program for the FCPA? Volkov’s Proposal

At the " Examining Enforcement of the Foreign Corrupt Practices Act " hearings on November 30, 2010, before the US Senate Judiciary Committee , Subcommittee on Crime and Drugs, Michael Volkov presented an interesting idea which he believes...

Doug Cornelius
Job Description For CCOs of Advisers to Private Investment Funds

Back in 2005, Associate Director Office of Compliance Inspection and Examinations of the SEC, Gene Gohlke gave a speech addressing hedge funds who would soon have to register under the doomed hedge fund rule. He focused on what the funds needed in...

Thomas O. Gorman
FCPA Enforcement: Crafting Incentives to Foster Compliance

FCPA enforcement has been marked by the aggressive approach adopted in recent years by The Department of Justice and the SEC. As Acting Deputy Assistant Attorney General Greg Andres told a Senate Committee this week "over approximately the last...

Doug Cornelius
Calculating Regulatory Assets Under Management for Private Funds

For private fund managers, one troubling aspect of Form ADV had been the calculation of "assets under management" in item 5.F. If securities are less than 50% of the portfolio then the portfolio would not be a securities account. Except...

Kevin M. LaCroix
Can a D&O Insurer Seek to Recoup Prior Settlement Payments from Its Own Insured?

Settlement is the critical goal in every claim that cannot be resolved otherwise. It terminates the open dispute, it provides the parties with finality, and, perhaps, most importantly, it provides the parties with repose. After a settlement is final...

Brian JM Quinn
Bad Accountants

With all the interest in the ongoing Galleon/SAC/expert networks insider trading investigation, this run of the mill scam almost slipped past. Thankfully this one doesn't involve lawyers - just bad accountants and traders. The SEC charged a former...