UPDATE: The SEC will wait a week. A new meeting has been scheduled for August 29. At today’s meeting the Securities and Exchange Commission is set to consider a rule on lifting its longstanding ban on general solicitation and advertising for privately-issued securities. Item 3: The Commission will consider rules to eliminate the prohibition against … Read more »

FBI and Understanding White Collar Criminals
As part of my visit to the FBI Headquarters for the FBI Corporate Compliance Officer Outreach Event, Supervisory Special Agent Susan Kossler discussed her work in the Behavior Analysis division of the FBI. The Silence of the Lambs and “Criminal Minds” have glamorized the work of FBI profilers, making them seem like real life versions … Read more »
The FBI’s Compliance Program
As I mentioned last week, I had a chance to meet with the Federal Bureau of Investigation and learn about their compliance program and some aspects of other FBI programs. Patrick W. Kelley gave a very thoughtful overview of the FBI’s compliance program. Like many compliance programs, it was born from a crisis. The FBI … Read more »

Compliance Bits and Pieces – Standard Chartered Edition
The British bank Standard Chartered found itself in trouble for dealing with Iranian customers in violations of US sanctions. Here are some stories that covered the news. Best. Quote. Ever. From Howard Sklar’s Open Air Blog Preparing for This Week in FCPA today, I came across this quote in the New York State Department of … Read more »

My Visit with the FBI
You would expect a visit with the FBI to be terrifying. When they come with their badges out and windbreakers on, you are in trouble. The FBI headquarters is easy spot, sitting right on Pennsylvania Avenue in Washington, D.C. Even once you get past the security guards and metal detectors in the front lobby, visitors … Read more »
Compliance Bits and Pieces for August 10
These are some of the compliance-related stories that caught my attention. Anti-Money Laundering For the Non-Banking Entity by Tom Fox While many companies which operate under anti-bribery laws such as the UK Bribery Act or anti-corruption laws such as the US Foreign Corrupt Practices Act (FCPA), have compliance programs in place to review business relationships, I … Read more »
Vanderbilt: The First Tycoon
There were the rich, the super rich, and Cornelius Vanderbilt. T.J. Stiles takes you through the life of the Commodore in The First Tycoon: The Epic Life of Cornelius Vanderbilt. Sons are notoriously prone to exaggerate the importance of their fathers, as are biographers with their subjects… Vanderbilt founded a dynasty. The First Tycoon starts … Read more »
Transaction Account Guarantee program and Risk Management
The Transaction Account Guarantee program was originally launched in 2008 by the Federal Deposit Insurance Corp. to help banks hold on to liquidity. The program gives unlimited federal guarantees to zero-interest bank deposits. This allows companies to park cash and not worry about the bank failure. Given the current low interest environment, giving up the … Read more »
Compliance Bits and Pieces for August 3
These are some of the compliance-related stories that recently caught my attention. Four Signs Your Awesome Investment May Actually Be A Ponzi Scheme by Theo Francis in NPR’s Planet Money [I]t turns out that the Ponzi industry is much broader and deeper than even the biggest blowups suggest. That’s one lesson of a slim new … Read more »
Badminton Falls Down
Few in the United States watch Olympic badminton. Fewer still are likely to watch after the ridiculous play in preliminary games. (Maybe a few will try to watch, just as a few slow down to watch the results of a car accident on the side of the road.) Four of the best teams in the … Read more »