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Thomas Fox
Provenance in the Supply Chain: Transparency and Accountability under the FCPA and Bribery Act

In the October 2010 issue of the Harvard Business Review there is a Spotlight article on " The Transparent Supply Chain ". In this article, author Stephen New discusses the evolution in Supply Chain from opaqueness to transparency and focuses...

Kevin M. LaCroix
D&O Insurance: Defense Costs Incurred in Informal SEC and Internal Investigations

Among the most frequently recurring and arguably most vexatious D&O insurance coverage issues are the questions of the carrier's obligation under the policy for defense expenses incurred either in connection with an informal SEC investigations...

Thomas O. Gorman
Making a Bad Day Worse

Former SEC Enforcement Director Steve Cutler once told a meeting of the DC Bar Association that "no matter how bad the underlying conduct, you can always make things worse." At the time Mr. Cutler was talking about failing to produce documents...

Thomas O. Gorman
Commissioner Aguilar Details Guiding Principles for the SEC

As the SEC continues to implement the Dodd-Frank Act, Commissioner Luis Aguilar outlined five key principles to guide the deliberations and actions of the agency. "An Insider's View of the SEC: Principles to Guide Reform," available ...

Doug Cornelius
SEC Complaint Reads Like a List of Things Not to Do

SEC complaints usually contain great stories about what you should not to do. A recent case involving PEF Advisors caught my eye. The SEC claimed that hedge fund managers Paul Mannion, and Andrew Reckles, and their investment advisory company PEF Advisors...

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Thomas Fox
Kroll Annual Global Fraud Report

One of the ways to increase market share is to build a mousetrap and it increasingly appears that one of the fastest ways to increase market share is to pilfer a company's plans for a better mousetrap. As reported in the October 18, 2010 online...