How Do You Exit a Ponzi Scheme?

It looks like Bernie Madoff was $45 billion short of funds in his “investment strategy.” How was he ever going to get out of this? The original Ponzi schemer, Charles Ponzi, seems to think he could get out of his situation, at least according to Mitchell Zukoff, author of Ponzi’s Scheme: The True Story of … Continue reading “How Do You Exit a Ponzi Scheme?”

Compliance Bricks and Mortar for March 28

These are some of the compliance-related stories that recently caught my attention. Encouraging Communication of Employee Concerns by Michael Volkov in Corruption, Crime & Compliance One of the hardest issues for compliance professionals is encouraging employees to raise concerns about ethics and compliance issues.  It has become even more difficult when the government establishes whistleblower … Continue reading “Compliance Bricks and Mortar for March 28”

Weekend Reading: Wheelmen

There are compliance lessons to be learned in Wheelmen: Lance Armstrong, the Tour de France, and the Greatest Sports Conspiracy Ever by Reed Albergotti and Vanessa O’Connell. Lance Armstrong was one of the best cyclists in last 20 years. But his wins were built on a foundation of illegal doping and performance enhancing drugs. It’s … Continue reading “Weekend Reading: Wheelmen

What Was It Called Before Mr. Ponzi Did It?

When Bernie Madoff’s fraud was exposed it was labeled a Ponzi scheme. Madoff was not investing the money as promised. He was using new investment money to pay old promised returns. I thought it would useful to look back at the original Ponzi scheme to see if offered insight to today’s world of compliance. I … Continue reading “What Was It Called Before Mr. Ponzi Did It?”

Compliance Bricks and Mortar – JP Morgan ALM Edition

JP Morgan paid $2 billion in fines and disgorgement for failing to file a suspicious activity report against Bernie Madoff. I provided my two cents. Here are some other views. The invincible JP Morgan by Felix Salmon This is sheer unmitigated — and, yes, probably criminal — incompetence. It takes a very special kind of … Continue reading “Compliance Bricks and Mortar – JP Morgan ALM Edition”

The Monsters of Compliance – Dracula

The pumpkins and garish Halloween decorations are out on my front lawn. With the Halloween season upon us, my mind has become stuck on movie monsters and been mixed with compliance. This is the terrible result. Vampires have taken many forms, mixing mythologies, weaknesses and desires. There is the regal version played by Bela Lugosi, … Continue reading “The Monsters of Compliance – Dracula”

Monsters of Compliance – Werewolf

The pumpkins and garish Halloween decorations are out on my front lawn. With the Halloween season upon us, my mind has become stuck on movie monsters and been mixed with compliance. This is the terrible result. The werewolf is old and widespread legend. Lycanthropes gain the ability to turn from human form into a wolf … Continue reading “Monsters of Compliance – Werewolf”

Unraveled: The Fall of Marc Dreier

Had it not been for Bernie Madoff, Marc Dreier would likely have been the most notorious fraudster of recent memory. The press coverage was stolen away from Mr. Dreier’s $3/4 billion scam by the billions Madoff stole. But Dreier’s theft was much more brazen and a lot crazier. Over the weekend, between shuttling the kids … Continue readingUnraveled: The Fall of Marc Dreier”

The Fall of Sam Israel

Sam Israel is a scumbag. He is a liar and a cheat. He admits so in Octopus by Guy Lawson. Israel was the nefarious trader behind the Bayou Funds, one of biggest hedge fund ponzi schemes, at least until Bernie Madoff finally fell to Earth. Lawson met with Israel while Israel was in prison. He … Continue reading “The Fall of Sam Israel”

The New Rule 506(d) and Bad Actors

At its latest meeting, the Securities and Exchange Commission approve the rule that lifted the ban on general solicitation and advertising for certain private placements. The SEC also adopted the new rule that disqualifies felons and other bad actors from participating in certain securities offerings. The first rule was mandated by the JOBS Act. The … Continue reading “The New Rule 506(d) and Bad Actors”