Did you know that Morgan Stanley's compliance communication program was an important part of DOJ and SEC's decision not to prosecute in the Garth Peterson case?
Abstract
The 2012 decision by the US Department of Justice and the US Securities & Exchange Commission to decline prosecution of Morgan Stanley for FCPA violations set off a wave of speculation about the agencies' compliance expectations. What made Morgan Stanley's compliance program different - different enough to warrant a declination? And, will that be enough going forward?
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