In responding to regulatory and government investigations, firms are often faced with the question of how to balance the desire to cooperate with the need to preserve privilege over an internal investigation. Financial institutions face this question additionally in their reporting requirements to regulators, including Form U-5 filings and Suspicious Activity Reports. Two recent decisions… Continue Reading
Due to the absence of instructive case law and interpretative guidance from the U.S. Securities and Exchange Commission (SEC), companies are often left in the dark with regard to whether and/or when they should publicly disclose that they are under investigation. The Southern District of New York recently provided much-needed guidance on the issue. On… Continue Reading
Based on these statistics, it seems fairly likely that some companies will learn the hard way about the benefits of putting in place a proper compliance program for anti-corruption risks when they are later investigated and prosecuted… Continue Reading
once you are being investigated by prosecutors you need to be prepared for a very long haul (possibly several years), high legal costs and a great deal of management time will be incurred, not to mention the media interest and damaging headlines… Continue Reading
So one might take the view that "here we are again" five years later more allegations of corruption; involving a Saudi Royal again; the only difference is it is a UK subsidiary of EADS/GPT, on this occasion, and not British Aerospace. Presumably the Cameron government is faced with the same sort of dilemma, with similar pressure from the Saudi government.… Continue Reading
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