On October 22, 2024, the SEC charged two current reporting companies, Unisys Corp. and Check Point Software Technologies, and two former public companies, Mimecast Limited and Avaya Holdings Corp., with making materially...more
10/31/2024
/ Civil Monetary Penalty ,
Compliance ,
Corporate Counsel ,
Corporate Governance ,
Cyber Attacks ,
Cyber Incident Reporting ,
Cybersecurity ,
Data Breach ,
Disclosure Requirements ,
Enforcement Actions ,
Form 8-K ,
Internal Controls ,
Misleading Statements ,
Publicly-Traded Companies ,
Securities and Exchange Commission (SEC) ,
Security and Privacy Controls
In September 2024, the DOJ’s Criminal Division released an updated Evaluation of Corporate Compliance Programs (ECCP) guidance document to address emerging risks. The ECCP serves as a roadmap for how DOJ evaluates a company’s...more
10/22/2024
/ Anti-Retaliation Provisions ,
Chief Compliance Officers ,
Compliance ,
Compliance Management Systems ,
Department of Justice (DOJ) ,
Internal Controls ,
Pilot Programs ,
Whistleblower Awards ,
Whistleblower Protection Policies ,
Whistleblowers ,
White Collar Crimes
On October 15, 2021, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued tailored sanctions compliance guidance for those operating in the virtual currency industry, including technology...more
10/21/2021
/ Compliance ,
Corporate Counsel ,
Digital Currency ,
Economic Sanctions ,
Financial Services Industry ,
New Guidance ,
Office of Foreign Assets Control (OFAC) ,
Regulatory Oversight ,
Risk Assessment ,
SDN List ,
Strict Liability ,
U.S. Treasury ,
Virtual Currency
The government has increasingly focused its FCPA enforcement firepower on individuals. On August 31, a Russian official living in Maryland pled guilty to conspiracy to commit money laundering in connection with arranging $2...more
9/24/2015
/ Bank of New York (BNY) Mellon ,
Compliance ,
Corporate Misconduct ,
Criminal Conspiracy ,
Defense Contracts ,
Department of Justice (DOJ) ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Official ,
Goodyear ,
Guilty Pleas ,
Internships ,
Money Laundering ,
Personal Liability ,
Securities and Exchange Commission (SEC)
The SEC has given the go-ahead to a venture capital firm’s plan to conduct 506(b) private placements online. On August 5, 2015, the Commission issued a no-action letter to Citizen VC, Inc., saying the firm’s proposed online...more
9/23/2015
/ Broker-Dealer ,
Compliance ,
Financial Institutions ,
Financial Markets ,
Investment ,
Investment Portfolios ,
Investors ,
No-Action Letters ,
Online Platforms ,
Private Placements ,
Regulation D ,
Rule 506(c) ,
Securities and Exchange Commission (SEC) ,
Securities Exchanges ,
Venture Capital
A CD or not a CD, That is the Question… That the Auditors Should Have Answered -
A headline-grabbing SEC enforcement action last week against BDO USA and several of its national partners may lead audit firms to insist on...more
9/18/2015
/ Auditors ,
Bank of New York (BNY) Mellon ,
Bribery ,
Compliance ,
Confidentiality Agreements ,
Construction Contracts ,
Criminal Conspiracy ,
Cybersecurity ,
Data Protection ,
Data Security ,
Defense Contracts ,
Department of Justice (DOJ) ,
Embezzlement ,
Enforcement Actions ,
Federal Trade Commission (FTC) ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Official ,
Fraud ,
Internal Investigations ,
Internships ,
Money Laundering ,
Nuclear Power ,
Private Placements ,
Regulation D ,
Rule 506(c) ,
Russia ,
SAP America Inc. ,
Securities and Exchange Commission (SEC) ,
Securities Litigation ,
Software ,
Sovereign Wealth Funds ,
Whistleblowers ,
Willful Misconduct