When thinking designing compliance programs, I pay extra attention to the issues that can result in jail time. It’s one thing to pay a fine, it’s a much bigger problem when you take someone’s freedom away.
The Dodd-Frank Wall Street Reform & Consumer Protection Act has added several new federal criminal offenses. The National Association of Criminal Defense Lawyers has compiled the two dozen provisions in a handy guide: Criminal Provisions in HR 4173 (list of the criminal provisions in Dodd-Frank Wall Street Reform & Consumer Protection Act)
.
Most of these new opportunities to earn a shiny pair of bracelets are related to the new regulatory regime of swaps.