Jane K. Storero and Yelena Barychev of The Legal Intelligencer and Law.com authored an article that the system of reviewing and monitoring information posted on a company Web site should be part of the disclosure controls included in the enterprise-wide risk management system established by the company: Corporate Governance of Public Web Sites. This article … Read more »
Tag: SEC
Counting Clients under the Investment Advisers Act – The Demise of the Hedge Fund Rule
Section 203(b) lays out the exceptions to registration under the Investment Advisers Act. Section 203(b)(3) exempts you if during the previous 12 months (i) you have fewer than 15 clients and (ii) you do not hold yourself out as an investment adviser. For private investment funds, the general partner is generally considered an investment adviser … Read more »
FCPA Allegation Against McCain Fundraiser
Republican fundraiser Harry Sargent III is subject to a suit from Supreme Fuels that Sargent’s company International Oil Trading Company made illegal payments to Jordanian officials. IOTC has an exclusinve license to move military fuel through Jordan. IOTC’s response, according to the NBC News Investigates story: . . .in an email to NBC News, a … Read more »
SEC Prosecutions under the Foreign Corrupt Practices Act
According to Linda Chatman Thomsen, director of the SEC’s Division of Enforcement, in a Forbes Article [The SEC in 2008: A Very Good Year?], the SEC filed 15 FCPA cases in 2008. Since January 2006, the SEC has brought 38 FCPA enforcement actions. That number is more than were brought in all prior years combined … Read more »