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Thomas O. Gorman
Insider Trading and Suspicious Trading, Not the Same

Investigating insider trading is difficult. Proving it is even more difficult. Frequently, the trading is "suspicious" because of its timing, magnitude, or for a variety of other reasons. Market watchers such as FINRA use this term to classify...

Thomas Fox
Promotional Expenses Defense under the FCPA

I. The Problem So what is the problem with a US company paying for travel, room and board for foreign governmental officials to travel to the United States? The problem is that payment for such travel, lodging and expenses may run afoul of the...

Doug Cornelius
Can Companies Do Well by Doing Good?

Yesterday's Wall Street Journal published a story by Aneel Karnani, Professor of Strategy at the University of Michigan's Stephen M Ross School of Business with a controversial headline: The Case Against Corporate Social Responsibility . ...

Thomas O. Gorman
Dodd – Frank: Credit Rating Agencies, Part II

Dodd-Frank focuses on the structure of credit rating agencies, requiring revisions and imposing other requirements in an effort to resolve the conflicts of interest and other difficulties many believe were at the center of the market crisis. The article...

Thomas Fox
Board Members and Prudent Discharge of Duties under the FCPA

Monday's FCPA Blog post wrote about what it called a "compliance donnybrook" inside the company China Northeast Petroleum. The facts of this melee are straight-forward, in July, the head of the Board of Director's Audit Committee...

Sutherland Asbill & Brennan LLP
Impact of Dodd-Frank Wall Street Reform and Consumer Protection Act on Broker-Dealers

by Susan S. Krawczyk, Eric A. Arnold, Michael B. Koffler, Clifford E. Kirsch, and Holly H. Smith On July 21, 2010, President Obama signed the Dodd-Frank Wall Street Reform and Consumer Protection Act (the Act), bringing to a close the national debate...