“The largest single investigation and prosecution against individuals in the history of DOJ’s enforcement of the Foreign Corrupt Practices Act” The Department of Justice has gotten serious about the FCPA. “This ongoing investigation is the first large-scale use of undercover law enforcement techniques to uncover FCPA violations and the largest action ever undertaken by the … Read more »
SEC’s New Enforcement Cooperation Initiative
The Securities and Exchange Commission announced a new initiative encouraging cooperation. They put on a big media blitz. Big enough that they even allowed me to ask a question of SEC Enforcement Director Robert Khuzami. For the first time, the SEC set out how it will evaluate whether, how much, and in what manner to … Read more »
Social Networking is Serious Business – Presentation Materials
I joined John Pepper, the CEO of Boloco and Russ Edelman the CEO of Corridor Consulting at meeting of the New England Chapter of AIIM on Friday. The topic was “Social Networking is Serious Business.” Russ started us off with a great background on Web 2.0 and social networking tools. Here is the slidedeck he … Read more »
Martin Luther King, Jr.
I Have a Dream – Address at March on Washington August 28, 1963. “I have a dream that one day this nation will rise up and live out the true meaning of its creed: ‘We hold these truths to be self-evident, that all men are created equal.’” “Let freedom ring. And when this happens, and … Read more »
Compliance Bits and Pieces for January 15
Here are some interesting compliance, risk and ethics stories from the past week: Robert Kennedy, the Travel Act and the FCPA by Thomas Fox in Tfoxlaw’s Blog Robert Kennedy’s contribution is that while Attorney General, he urged Congress to enact the Travel Act in 1961 which was passed as part of the same series of … Read more »
New Social Media Policies Database
I assembled a collection of social media policies: Social Media Policies Database. So far I have 117 a bunch in the database. That’s a very small number, but I think most companies want to keep their policies private. If I am missing any, please leave a comment letting me or send me an email: [email protected]. … Read more »
Questions and Answers with Robert Khuzami
After the news conference announcing the Rearrangement of its Enforcement Program, the Securities and Exchange Commission offered a group of bloggers the chance to ask questions to Robert Khuzami, the Director of Enforcement. (It must have felt like Obi-Wan stepping into the cantina full of low-life scoundrels.) The blogging participants: Todd Sullivan of Value Plays … Read more »
SEC Rearranges its Enforcement Program
The Securities and Exchange Commission reorganized its enforcement division. Enforcement Director Robert Khuzami announced a new program announced the creation of new units. First, the SEC are expanding the whisteblower program. They are calling it a “cooperation program.” Then there are five new units in the enforcement division. Asset Management Unit The unit specializing in … Read more »
SEC News Conference on its Enforcement Program
Bruce Carton of Securities Docket, Francine McKenna of Re: The Auditors and I are attending the SEC’s news conference virtually and taking notes using the CoverItLive tool embedded below. SEC Enforcement News Conference Read more »
Ethics of Congressional Stock Ownership
The Washington Post published a story using Congressman John Dinghell as an example of the ethics issues involved when you have an investor lawmaker: Dingells and GM illustrate limits of congressional conflict-of-interest rules. Kimberly Kindy and Robert E. O’Harrow Jr. use Congressman Dinghell because of his financial connection with General Motors. This connection was one … Read more »