Compliance into the Weeds-Episode 24
In this episode Matt Kelly and myself take a deep dive into the compliance weeds by looking at a paper written by then SEC General Counsel James Doty (later head of the PCAOB) in 2007 where he proposes...
View ArticleFCPA Compliance Report-Episode 299, Philip Urofsky on Sherman & Sterling’s...
In this episode, I visit with Shearman & Sterling partner Philip Urofsky who leads a team which produced the 2017 FCPA Digest, one of the top annual compendium of annual FCPA reviews of the prior...
View ArticleThis Week in FCPA-Episode 35
Show Notes for Episode 35, week ending January 13, the Friday the 13th edition: Hernandez and Beech FCPA guilty pleas. Hernandez Criminal Information, Beech Criminal Information. VW guilty plea in...
View ArticleRecidivism Under the FCPA: Zimmer Biomet
Last week Zimmer Biomet Holdings, Inc. paid a high price for its and its predecessors failure to comply with the terms and conditions of 2012 Deferred Prosecution Agreement (the “2012 DPA”). Biomet,...
View ArticleCompliance into the Weeds-Episode 25
In this episode Matt Kelly and I take a deep dive into a couple of recent SEC enforcement actions. The first involved L-3 Technologies and accounting irregularities. The second involves BlackRock and...
View ArticleEverything Compliance-Episode 5, Year End Wrap-Up Part II
Show Notes for Episode 5, Year End Review, Part II We turn to the 2016 year in review, in this Part II of a two-part series. Jonathan Armstrong leads a discussion on Privacy Shield, information and...
View ArticleRolls-Royce Global Enforcement Action: Part IV – What Does it all Mean?
Today I conclude my series on the Rolls-Royce global anti-corruption enforcement action by taking a look what it all means going forward. The resolution is more than simply the stunning fines and...
View ArticleFCPA Compliance Report-Episode 303, Greg Keating on great upcoming...
2016 was more than simply the most robust year in Foreign Corrupt Practices Act (FCPA) enforcement. It was also a record year in Securities and Exchange Commission (SEC) whistleblower awards and...
View ArticleThis Week in FCPA-Episode 37, the Jeff Sessions Edition
Show Notes for Episode 37, week ending January 27, the Jeff Sessions’ edition Brazilian Judge killed in plane crash. See article by Dick Cassin in the FCPA Blog. Two individuals charged in Och-Ziff...
View ArticleCompliance Into the Weeds-Episode 26, is CCO liability real?
In episode Matt Kelly and I take a deep dive into a recent SEC enforcement action involving Susan Diamond, a CCO at a financial advisory firm. She made representations on forms submitted to the SEC...
View ArticleEverything Compliance-Episode 7
This episode is dedicated to the chaotic (at best) first three weeks of the Trump administration. Jonathan Armstrong leads a discussion of the Trump administrations devolution towards Privacy Shield...
View ArticleThis Week in FCPA-Episode 40, the Worse than Useless Edition
Show Notes: The SFO announces an investigation into the Swiss engineering giant ABB, Ltd. for allegations of corruption coming out of the Unaoil scandal. See article in the FCPA Blog. Former Magyar...
View ArticleThis Week in FCPA-Episode 47, the Season Opener Edition
In this episode, Jay and I have a wide-ranging discussion on some of the week’s top FCPA and compliance related stories. We discuss: Wrap up from the SCCE European Compliance and Ethics Institute. SEC...
View ArticleThe FCPA at 40 – FCPA Enforcement and the International Fight Against Bribery
In two speeches last week Department of Justice (DOJ) Acting Principal Assistant Attorney General Trevor McFadden addressed multiple topics and issues around the Foreign Corrupt Practices Act (FCPA)....
View ArticleCompliance Evangelist Hits the Road
In addition to prolific writing about compliance another area I committed to as the Compliance Evangelist is to speak about compliance in a variety of forums. In May, I have several speaking events and...
View ArticleEverything Compliance-Episode 10, the first 100 Days of the Trump...
This episode is the first of a two-part series of podcasts dedicated to the first 100 days of the Trump administration as it related to compliance. Today we have Jonathan Armstrong and Jay Rosen. Next...
View ArticleThe Kokesh Decision – One Question Answered, Others Left Open
In the case of Kokesh v. SEC, the US Supreme Court held the profit disgorgements operate as a penalty under the Securities and Exchange Act of 1934, as amended. As such “any claim for disgorgement in...
View ArticleFCPA Compliance Report-Episode 332, Marc Bohn on the Kokesh Decision
In the case of Kokesh v. SEC, the US Supreme Court held the profit disgorgements operate as a penalty under the Securities and Exchange Act of 1934, as amended. As such “any claim for disgorgement in...
View ArticleThis Week in FCPA-Episode 56
This week, Jay and I have a wide-ranging discussion on some of the week’s top compliance related stories. We discuss: The Kokesh case at the US Supreme Court is significant for SEC enforcement of the...
View ArticleFCPA Compliance Report-Episode 338, Steven Durham on the Whistleblower...
In this episode, I visit with Steven Durham, a partner in the law firm of Labaton Sucharow. The firm is one of the leaders in the SEC Whistleblower practice. Durham describes his background and how he...
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