News & Analysis as of

Internal Controls Disgorgement

ArentFox Schiff

Liberty Mutual Resolution Shows Route to Declination and Roadmap for Compliance Investments

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The US Department of Justice (DOJ) declined to prosecute Liberty Mutual after the insurer voluntarily self-disclosed misconduct....more

Nutter McClennen & Fish LLP

Nutter Securities Enforcement Update: Oct. 1 Quarterly Review

The Nutter Securities Enforcement Update is a periodic update of noteworthy recent securities enforcement activity, settlements, decisions, and charges. We provide brief summaries that highlight recent enforcement action...more

Morrison & Foerster LLP

Top 10 International Anti-Corruption Developments for November 2023

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Designed for busy in-house counsel, compliance professionals, and anti-corruption lawyers, this newsletter summarizes some of the most important international anti-corruption law and enforcement developments from the past...more

Nutter McClennen & Fish LLP

Nutter Securities Enforcement Update: October 1, 2022

The Nutter Securities Enforcement Update is a periodic summary of noteworthy recent securities enforcement activity, settlements, decisions, and charges. ...more

Nutter McClennen & Fish LLP

Nutter Securities Enforcement Update: September 1, 2022

The Nutter Securities Enforcement Update is a periodic summary of noteworthy recent securities enforcement activity, settlements, decisions, and charges. ...more

King & Spalding

SEC Brings Action Against Morningstar Alleging Undisclosed CMBS Rating Adjustments

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On February 16, 2021, the SEC filed a litigated civil complaint in the Southern District of New York against Morningstar Credit Ratings LLC, a former Nationally Recognized Statistical Rating Organization (“NRSRO”) alleging...more

Jones Day

U.S. Supreme Court Allows Profits-Based SEC Disgorgement Awards

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The Court holds that the Securities and Exchange Commission ("SEC") can continue to seek disgorgement from wrongdoers, while narrowing the remedy to net profits that are returned to victims. In Liu v. SEC, 591 U.S. ___...more

McDermott Will & Schulte

[Webinar] Anti-Corruption and Compliance Training - May 28th, 10:00 am - 11:30 am EDT

Please join McDermott and Grant Thornton on Thursday, May 28, for a webinar training on anti-corruption and compliance. This training will discuss the auditing standards on illegal acts by clients and the auditor’s...more

The Volkov Law Group

Cardinal Health Pays SEC $8.8 Million for FCPA Violations

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Cardinal Health (“Cardinal”) agreed to pay the SEC $8.8 million for FCPA violations in China relating to its internal controls and books and records. Cardinal acknowledged facts relating to internal controls deficiencies and...more

Skadden, Arps, Slate, Meagher & Flom LLP

Ericsson Agrees To Pay Over USD $1 Billion To Settle FCPA Charges

On December 6, 2019, Telefonaktiebolaget LM Ericsson (Ericsson or the Company), resolved long-running investigations by the U.S. Department of Justice (DOJ) and the U.S. Securities and Exchange Commission (SEC) into the...more

Thomas Fox - Compliance Evangelist

Top SEC Enforcement Actions from 2019

Yesterday, I considered five Department of Justice (DOJ) Foreign Corrupt Practices Act (FCPA) enforcement actions. Today, I want to look at key FCPA enforcement actions by the Securities and Exchange Commission (SEC)....more

Thomas Fox - Compliance Evangelist

Juniper Networks FCPA Enforcement Action-Speak Sternly and Enhance Controls

Last week Juniper Networks, Inc. (JNPR) resolved their long-standing Foreign Corruption Practices Act (FCPA) enforcement action by settling with the Securities and Exchange Commission (SEC) via a Cease and Desist Order...more

Thomas Fox - Compliance Evangelist

Walmart FCPA Enforcement Action: Part 1 – Introduction

The big one finally is resolved. The long-awaited Walmart Inc. (Walmart) Foreign Corrupt Practices Act (FCPA) enforcement action was announced yesterday. This massive case came in with multiple documents, a long list of...more

Holland & Knight LLP

Petrobras Agrees to Pay More Than $1.8 Billion for Facilitating FCPA Violations

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• Four years ago, Brazilian authorities began Operation Car Wash, a wide-ranging and still ongoing corruption and money laundering investigation that has spanned 11 countries. • The fallout continues with a recent U.S....more

The Volkov Law Group

Petrobas Closes Out “Massive” Corruption Investigations and Litigation

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When it comes to a poster-child for corrupt organizations, there is very little competition that can eclipse Petrobas, the Brazilian state-owned oil and gas company. ...more

Broker-Dealer Compliance + Regulation

First State Charges Broker-Dealer in Connection with Violations of DOL Fiduciary Rule

On February 15, 2018, the Enforcement Section of the Massachusetts Securities Division (the “Division”) of the Office of the Secretary of the Commonwealth charged a registered broker-dealer (the “Broker-Dealer”) that operated...more

The Volkov Law Group

Lessons Learned From FCPA Enforcement Against JP Morgan for Sons and Daughters Referral Program

The Volkov Law Group on

Last week, the Justice Department and the SEC finally brought to a close the Sons and Daughters or Princelings investigation. Pending investigations against four other companies still remain to be resolved....more

Thomas Fox - Compliance Evangelist

Embraer FCPA Enforcement Action – Part III

Today I continue my exploration of the recently announced Department of Justice (DOJ) and Securities and Exchange Commission (SEC) Foreign Corrupt Practices Act (FCPA) enforcement action with the announcement of the...more

Thomas Fox - Compliance Evangelist

John Fogarty Rocks-Nu Skin Informs Oversight

I recently saw John Fogerty in concert. For those you are not aware, he was a founding member and the driving force behind Creedence Clearwater Revival (CCR), one of the very top American groups from the 1960s and early...more

Perkins Coie

Issuer Reporting and Disclosure Remains Focus of SEC and Other Regulators

Perkins Coie on

In a recent speech, SEC Enforcement Director Andrew Ceresney confirmed the SEC’s continued pursuit of investigations and enforcement actions relating to issuer reporting and disclosure, an area that remains a high priority...more

Thomas Fox - Compliance Evangelist

Declinations and Profits Disgorgement – It Was There All Along

Last week there were two declinations issued by Department of Justice (DOJ) for Foreign Corrupt Practices Act (FCPA) matters. The matters involved two Texas based, privately held companies. The first was HMT LLC (HMT) which...more

Orrick, Herrington & Sutcliffe LLP

This Cold Bud Is For You: SEC Sanctions Anheuser-Busch for “Chilling” Employee from Communicating with SEC

On September 28, 2016, the SEC announced that Anheuser-Busch agreed to pay $6 million to settle charges of Foreign Corrupt Practices Act and Dodd-Frank whistleblower violations. The SEC’s order stated that AB InBev violated...more

Thomas Fox - Compliance Evangelist

Anheuser-Busch InBev and Lessons in Joint Venture FCPA Compliance

Just in time for National Beveridge Day comes the Foreign Corrupt Practices Act (FCPA) enforcement action involving Anheuser-Busch InBev (ABI), where the company paid $6 million to settle charges that it violated the FCPA and...more

The Volkov Law Group

Five Key Takeaways from Key Energy’s SEC FCPA Settlement

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The SEC, last week, announced its $5 million settlement with Key Energy. As always, FCPA settlements contain important examples of enforcement priorities and policies. Key Energy’s recent settlement is an example of the...more

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