The Honorable Henry E. Hudson, U.S. District Judge for the U.S. District Court for the Eastern District of Virginia struck an ominous note for individuals facing FCPA scrutiny when he handed down the stiffest individual penalty to date at the April 19, 2010 sentencing of Charles Paul Edward Jumet. Jumet was given 87 months (over… Continue Reading
More than two years have passed since Congress enacted legislation requiring all businesses with in-house lobbyists to comply with the Congressional gift rules. Yet, many businesses are still unsure about how to comply with these rules, which were not originally designed to apply to anyone outside Congress. What can businesses do to comply? The latest… Continue Reading
There is good reason, beyond anger, voyeurism and schadenfreude, for Wall Street and “Main Street” to keep their eyes on the SEC enforcement action against investment banking firm Goldman Sachs & Co and one of its vice presidents, Fabrice Tourre. According to the SEC’s complaint (pdf), Goldman was paid by one of the world’s largest hedge funds, Paulson… Continue Reading
On April 23, 2010, Arizona Governor Jan Brewer signed an immigration bill entitled, “Support Our Law Enforcement and Safe Neighborhoods Act,” (pdf) which among other things, requires state and local law enforcement officials to reasonably attempt to determine the immigration status of a person with whom they have lawful contact and reasonable suspicion that the… Continue Reading
Federal prosecutors recently announced the first criminal prosecution for fraud under the Troubled Asset Relief Program (“TARP”). Charles Antonucci, the former president of the Park Avenue Bank of New York, was arrested and will be prosecuted in the Southern District of New York on charges of embezzlement, bribery and allegedly trying to defraud the TARP program of $11.2 million.… Continue Reading
It’s been more than several weeks since the Administration indicated that a decision on whether Khalid Sheikh Mohammed will be tried in a federal court or military commission was weeks away. Of course, this will be the second decision on the issue – Attorney General Eric Holder first announced that KSM and his 9/11 co-conspirators would… Continue Reading
In the past month, federal prosecutors opened a new front in their battle against financial misconduct with the announcement of the first criminal prosecution for fraud under the Troubled Asset Relief Program (TARP). Charles Antonucci, former president of the Park Avenue Bank of New York, was arrested Monday morning and charged with embezzlement, bribery, and allegedly… Continue Reading
You need to follow along closely because this can get a bit confusing. As we all recall, in 2003, judgments were entered against 12 of the largest Wall Street firms that issued research and engaged in investment banking, commonly referred to as “The Global Settlement.” The Global Settlement imposed signficant restrictions on interactions between the research analysts and investment bankers… Continue Reading
Beware businesses that file lobbying disclosure forms. Roll Call’s Alex Knott writes that many businesses are still making a common mistake when calculating the lobbying expenses disclosed on their forms. Line 13 of Form LD-2 requires businesses with in-house lobbyists to disclose their quarterly lobbying expenses. Some businesses have taken this to mean only their in-house lobbying… Continue Reading
Oh the tangled web our government weaves. One might assume that the Department of Homeland Security’s Immigration and Customs Enforcement (ICE) agency is the only entity that will appear on the doorstep asking to inspect Form I-9s and conducting an immigration-related investigation. However, immigration enforcement actions can start through inspections by a number of different… Continue Reading
In 2005, ICE’s budget (pdf) was $3.56 billion. For 2010, it is $5.74 billion (pdf) — an increase of $2.18 billion! In a time when most most budgets are decreasing, ICE’s budget has increased by 60% in 5 years. That can only mean that immigration enforcement remains a priority for the federal government. Like it or not,… Continue Reading
On March 1, 2010, FINRA issued its 2010 annual examination priorities letter to all FINRA member firms. (pdf). This year’s letter is no different from past years in that it highlights areas that FINRA’s examination program will be focusing on throughout the coming year. These areas include some that we see from year-to-year; e.g., information barriers,… Continue Reading
After several years of criticism over lax enforcement of existing anti-corruption laws, and more than a decade of failed efforts to pass similar legislation, the UK is on the verge of passing comprehensive anti-bribery legislation. The UK Bribery Bill is modeled after but reaches beyond the United States’ Foreign Corrupt Practices Act (FCPA), U.S. legislation… Continue Reading
On March 23, 2010, a federal jury in the Western District of North Carolina, which encompasses Charlotte and Asheville, convicted a Nigerian citizen on conspiracy and wire fraud charges in connection with an “advance-fee” scheme that involved the use of money services businesses (MSBs) to transfer money. In its press release, the U.S. Department of Justice described the scam as… Continue Reading
Given your strong business ties with France, we believe you will be interested in the latest information on the new UK Bribery Bill, which will affect corporate compliance in UK and French organisations conducting business with the UK once enacted. The Bill has completed its passage through the House of Lords after three readings and… Continue Reading
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