Subject to Inquiry

Subject to Inquiry

THE LATEST ON GOVERNMENT INQUIRIES AND ENFORCEMENT ACTIONS

Government Investigations and White Collar Litigation Group

Tag Archives: enforcement

Enforcement and Prosecution Policy and Trends

Mulvaney’s First New Enforcement Action Continues Focus on Asset-Advance Firms

In the latest sign of regulatory scrutiny of asset-advance companies offering consumers what regulators believe are in fact regulated “credit” under federal law and “loans” under state law, the Bureau of Consumer Financial Protection (BCFP) filed its first new lawsuit under Acting Director Mulvaney last Thursday. The complaint, filed in the Central District of California,… Continue Reading
Enforcement and Prosecution Policy and Trends, Financial Institution Regulation, Fraud, Deception and False Claims

Will 2017 Be the Year of Insider Trading Reform?

For several years running, insider trading has been among the most high-profile enforcement priorities for both DOJ and the SEC. Unlike most federal criminal law, insider trading remains undefined by statute, having instead been largely judge-made. Unsurprisingly, since the explosion of enforcement actions began, prosecutors and defendants have both pushed the courts to clarify (or… Continue Reading
Compliance, Enforcement and Prosecution Policy and Trends

SEC: $7 Million Award to be Split by Three Whistleblowers

On Monday, January 23, 2017, the Securities and Exchange Commission (SEC) awarded more than $7 million to be split among three whistleblowers.  The three individuals helped the SEC in its investigation and prosecution of an investment scheme. The identity of whistleblowers is protected by law however, the SEC did disclose that the primary whistleblower will… Continue Reading
Anti-Money Laundering, Compliance, Financial Institution Regulation

FinCEN Associate Director for Enforcement Delivers Remarks at Title 31 Conference, Stresses Importance of Culture of Compliance

On the day after his appointment in August 2016, the Associate Director for Enforcement for the Financial Crimes Enforcement Network (FinCEN), Thomas Ott, addressed the National Title 31 Suspicious Activity & Risk Assessment Conference in Las Vegas, Nevada.  In his remarks, he (1) covered recent enforcement actions, (2) sought to dispel myths or misconceptions about… Continue Reading
Enforcement and Prosecution Policy and Trends

SEC Announces Settlement with Investment Advisory Firm Regarding Alleged Failure to Disclose Costs to Investors

On July 14, 2016, the Securities and Exchange Commission announced the settlement of an enforcement action against RiverFront Investment Group (“RiverFront”), an investment advisory firm, for failing to properly prepare clients for transaction costs. At issue is a wrap fee program, in which a subadviser uses a sponsoring brokerage firm to execute their trades on… Continue Reading
Anti-Bribery and Corruption, Compliance, Enforcement and Prosecution Policy and Trends, Financial Institution Regulation

Anticorruption compliance is more than adopting a policy

When the prosecutors come knocking on the door with a search warrant, one of the first things they will look for is evidence as to whether the company adhered to and fulfilled the six principles of adequate procedures. If one or more of those six steps is missing, the company may have no defence to a prosecution… Continue Reading
Anti-Bribery and Corruption, Compliance, Enforcement and Prosecution Policy and Trends, Financial Institution Regulation, Fraud, Deception and False Claims

BP receives whistleblower letter alleging corruption in its tanker division

The SFO has repeatedly said that it has been looking for a large, high profile international company to pursue in order to send a message around the world that it is serious about its enforcement under the Bribery Act. Could this be one of those cases?… Continue Reading
Enforcement and Prosecution Policy and Trends

MABEY AND JOHNSON – SFO OBTAINS CIVIL RECOVERY ORDER AGAINST SHAREHOLDER

The Serious Fraud Office has taken action in the High Court under Part 5 of the Proceeds of Crime Act which has resulted in an Order for a parent company, Mabey Engineering (Holdings) Ltd, to pay £131,201 in recognition of sums it received through share dividends derived from contracts won through unlawful conduct by one of its subsidiaries, Mabey and Johnson Limited, in which it was a principal shareholder.… Continue Reading
Anti-Bribery and Corruption, Compliance, Election and Political Law, Enforcement and Prosecution Policy and Trends

“No endemic corruption in the police service” – a new report on the British police

It is clear that the police, like employees in commercial organisations all around the world, need to receive much better training and much clearer guidance from their employers as to what is acceptable and what is not in order to avoid the suspicion of corruption… Continue Reading

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