Compliance Communications Blog

 

"Welcome to Our Company...Maybe"


10/7/15: Hiring personnel is an HR responsibility but, as with so many other business functions, it can easily become an FCPA risk for the company. Recent actions by the SEC against financial institutions for their hiring practices should heighten every company’s awareness of the potential risks involved in hiring foreign...

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"Subject: Individual Accountability for Corporate Wrongdoing"

 

9/15/15: That’s the subject line in a recent memo from DOJ to federal prosecutors.  The memo spells out a new policy for aggressively investigating and prosecuting individuals involved in corporate crimes. In a notable shift from DOJ’s traditional focus on prosecuting corporations, the memo sets...

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"Prevent and Detect Violations"

 

9/1/15: The US Securities and Exchange Commission recently settled charges with Citigroup Global Markets saying the company failed to adopt and apply procedures that would prevent and detect transactions signaling the potential misuse of material, nonpublic information. The company also failed to adopt...

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"SEC Continues to Tackle FCPA Violations"

 

9/1/15: The Securities and Exchange Commission isn’t fooling around with its enforcement of the FCPA. In the process, it’s also reminding compliance officers of the various ways they can run afoul of the law. Recently, the SEC announced a settlement with BNY Mellon to settle charges that it violated the FCPA by providing...

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"The FTC Tries to Clarify its Anti-Competition Principles"

 

8/19/15: Anti-competition law is a complicated business but the Federal Trade Commission has taken a stab at describing the underlying principles that guide its enforcement actions against “unfair methods of competition” prohibited by Section 5 the FTC Act.  According to FTC Chairwoman Edith Ramirez, “The statement...

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