You missed the warning signs and got suckered into a Ponzi scheme. The IRS offered some tax relief for long-term Ponzi scheme investors (like some of the Madoff victims) who have paid taxes on gains from the investment. The IRS clarified the federal tax law governing the treatment of losses in Ponzi schemes. They also … Read more »
The SEC’s Office of Inspector General and Form D
The SEC’s Office of Inspector General has released its Semiannual Report to Congress (.pdf). I started off looking at how the OIG feels about the new Form D for securities sold under the Regulation D exemption: “Based on our review of Form D, we determined that certain revisions should be made to the form to … Read more »
What Blogging Brings to Business
This post is republished from my original post on KM Space on June 10, 2008: What Blogging Brings to Business. Blogs are powerful communication platforms that allow you to capture information you find interesting and to share it with an “audience” who can talk back to you. This panel of five business bloggers with a … Read more »
Principles of Federal Prosecution of Business Organizations
At last week’s Compliance Week Conference, I saw a paradigm shift in thinking about the factors to be included in a compliance program. Most compliance programs have placed a lot of emphasis on the federal sentencing guidelines. After all, those guidelines give credit for having an effective compliance program. So you want to have an … Read more »
Enterprise 2.0 at Goodwin Procter
Can law firms jump on the Enterprise 2.0 bandwagon? Lawyers are generally seen as conservative users of technology, preferring to use a quill and inkwell over a web-based publishing platform. David Hobbie shares some of the successes he has encountered in the adoption of Enterprise 2.0 at Goodwin Procter (.pdf – page 13) in the … Read more »
FCPA Visualization
The number of Foreign Corrupt Practices Act charges and the size of the penalties have surged recently. The James Mintz Group pinpointed the location of every bribe that has led to an FCPA case in the last 10 years and illustrated them graphically. The countries that have generated the most FCPA cases in the last … Read more »
Wrap Up of Compliance Week Conference
It was a great few days in Washington D.C. at my first Compliance Week Conference. The conference was packed with great presentations and discussions over its three days. In particular, it was great to spend time with Bruce Carton, Francine McKenna, Scott Cohen, Matty Kelly and Alex Howard. Below are links to some stories from … Read more »
Conversation with Harvey Pitt
This was another “dark session” with about 30 compliance professionals sitting down for an informal discussion with former SEC Chairman Harvey Pitt. I am not going to share detailed notes, just some general issues that were discussed, with no attribution to any individual. Compliance is really about non-compliance. The only reason compliance is relevant is … Read more »
Your Compliance Program and Enforcement
This session at Compliance Week Conference 2009 was another “dark session” so I am not sharing detailed notes, merely a perspective on some issues that were presented. John Roth, an Assistant U.S. Attorney in the Fraud and Corruption Section shared his insights and Bruce Carton did his best Phil Donahue impression by eliciting questions from … Read more »
Compliance Week Keynote from David Ogden
My notes, live, from the keynote address by David Ogden, the Deputy Attorney General. As we confront the current financial crisis and try to restore trust and accountability, we have a shared responsibility to make sure justice is done. Responsible corporate behavior must be encouraged and rewarded. There will continue to enforcement action on financial … Read more »