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
On April 21, 2015, the Consumer Financial Protection Bureau (CFPB) and the Federal Trade Commission (FTC) announced a joint enforcement action and joint order with a national mortgage servicer. The CFPB and FTC alleged that the servicer failed to honor loan modifications transferred from other servicers and insisted that borrowers pay their original, higher monthly… Continue Reading
On 1 November 2011, the SFO launched a confidential hotline (called "SFO Confidential") together with an online reporting form to facilitate reporting suspected fraud or corruption.… Continue Reading
The SEC and DOJ regularly enter into binding settlement and plea agreements to resolve fraud and corruption matters in both civil and criminal contexts.… Continue Reading
At a time when many are questioning the SFO's budget and ability to fund and pursue multiple large scale corruption investigations, the settlement with Macmillan demonstrates that SFO investigations can reach an outcome in a timely and cost effective manner. The model followed for the Macmillan investigation is likely to be replicated for investigations into offences under the Bribery Act.… Continue Reading
Although there have been many hundreds of prosecutions under the FCPA, particularly over the past 10 years or so, this was, we are told, the first such case against a company which had made it all the way to a jury trial.… Continue Reading
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