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DC Circuit Reverses SEC - Negligent Omissions And Willful Omissions Are Mutually Exclusive
On April 30, 2019, the U.S. Court of Appeals for the D.C. Circuit held that an investment adviser (IA) cannot willfully make a negligent disclosure in its Forms ADV.
United States
21 May 2019
2
DC Circuit Reverses SEC Finding That Negligent Omissions And Willful Omissions Are Mutually Exclusive
On April 30, 2019, the U.S. Court of Appeals for the D.C. Circuit held that an investment adviser (IA) cannot willfully make a negligent disclosure in its Forms ADV.
United States
17 May 2019
3
Second Circuit Rejects DOJ's Expansive Theory Of Conspiracy And Accomplice Liability Under The FCPA For Foreign Nationals
On August 24, 2018, nearly 18 months after hearing oral argument, the U.S. Court of Appeals for the Second Circuit issued a decision in United States v. Hoskins, ...
United States
7 Sep 2018
4
Foreign Corrupt Practices Act 2017 Year-End Update
2017 marked the fortieth anniversary of the Foreign Corrupt Practices Act (FCPA), and showed continued robust enforcement against both individuals and companies by the U.S. Department of Justice (DOJ)...
United States
12 Mar 2018
5
New SEC Enforcement Initiative Encourages Advisers To Self-Report Mutual Fund Share Class Violations
On February 12, 2018, the Division of Enforcement of the U.S. Securities and Exchange Commission ("SEC") announced a new initiative to encourage advisers to self-report share class violations.
United States
26 Feb 2018
6
DOJ Announces Revised Fcpa Corporate Enforcement Policy
The revised FCPA Corporate Enforcement Policy has two main components. First, the policy provides that if a company voluntarily self-discloses misconduct, fully cooperates...
United States
5 Dec 2017
7
Foreign Corrupt Practices Act 2017 Mid-Year Update
The first half of 2017 has been eagerly anticipated following the record-setting year in 2016 for Foreign Corrupt Practices Act ("FCPA") enforcement by both the U.S. Department of Justice...
United States
4 Sep 2017
8
Foreign Corrupt Practices Act 2016 Year-End Update
2016 was a record-setting year for Foreign Corrupt Practices Act ("FCPA") enforcement, as both the U.S. Department of Justice ("DOJ")...
United States
6 Feb 2017
9
FCPA Chief Touts Record High Enforcement Actions – Links Avoiding A Monitor To Early Remediation Of FCPA Issues
Appearing before the annual Securities Docket Conference in Washington, DC on October 13, Kara Novaco Brockmeyer, the Chief of the Securities and Exchange Commission's FCPA Unit, laid out the Commission's FCPA enforcement priorities, including insight on how to avoid an SEC-imposed monitor.
United States
25 Oct 2016
10
Foreign Corrupt Practices Act 2015 Year-End Update
Both the United States Department of Justice (DOJ) and the United States Securities and Exchange Commission (SEC) have continued their focus on anticorruption enforcement in 2015.
United States
25 Apr 2016
11
DOJ Attempts To Encourage Corporate Self-Disclosures With The Announcement Of A One-Year FCPA Pilot Program
The ultimate impact of the new policy, which is being previewed as a one-year "pilot," is unknown.
United States
20 Apr 2016
12
Clean Hands, Smart Deals: A Primer On Complying With Foreign Anti-Bribery Laws
BakerHostetler, in a showcase of our depth of experience, presented an informational seminar in June 2015 at the 51st Paris Air Show, the largest aerospace trade show in the world.
United States
20 Nov 2015
13
Managing Anti-Corruption And Export Control Risk In The Aerospace Industry
The U.S. Securities and Exchange Commission (SEC) and the U.S. Department of Justice (DOJ) have made no secret of their goal to heighten both civil and criminal enforcement of the FCPA.
United States
10 Jul 2015
14
No Room For Companies To Gamble As The Feds Double Down On FCPA Enforcement
In 2014, a record-setting year for Foreign Corrupt Practices Act (FCPA) enforcement, the Department of Justice (DOJ) announced the largest-ever DOJ FCPA resolution—an over $772 million criminal fine for French power company Alstom S.A.
United States
18 Apr 2015
15
Foreign Corrupt Practices Act 2014 Year End Update
Over the course of 2014, the Department of Justice ("DOJ") and the Securities and Exchange Commission ("SEC") have continued their aggressive enforcement of the Foreign Corrupt Practices Act ("FCPA").
United States
5 Mar 2015
16
Foreign Corrupt Practices Act 2014 Mid-Year Update
The first half of 2014 has seen several important developments in the enforcement of the Foreign Corrupt Practices Act ("FCPA") as well as other anti-corruption laws worldwide.
United States
27 Aug 2014
17
The FCPA On Steroids: Brazil Ups The Ante In Fighting Corporate Corruption
Recently, in the wake of massive protests throughout Brazil concerning corruption and other issues, Brazilian President Dilma Vana Rousseff dramatically increased anti-corruption prohibitions in Brazil by signing into law the Anti-Bribery Act or "Lei Anticorrupção."
United States
14 Aug 2013
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