Compliance Bits and Pieces for November 12

Here are some compliance-related stories that I found interesting:

Stanford Moved After More Fisticuffs Leaves Him Bruised and Bloodied by Ashby Jones in’s Law Blog

He was granted a transfer Monday from a private Texas jail to a federal one closer to his lawyers in downtown Houston. The transfer came in the wake of news that Stanford got into a fight with an inmate on Thursday, in which he suffered a concussion, two black eyes and a broken nose, according to his lawyer, Kent Schaffer.

NASAA Urges SEC to Adopt “Investments Owned” Accredited Investor Test in Jim Hamilton’s World of Securities Regulation

In a comment letter to the SEC, the North American Securities Administrators Association (NASAA) has urged the Commission to adopt an “investments owned” test for accredited investors in private offerings conducted under federal Regulation D.

The End of the FCPA Facilitation Payment Exception? by Tom Fox

The only countries that permit facilitation payments are the United States, Canada, Australia, New Zealand and South Korea. Facilitation payments, however, are illegal in every country in which they are paid. They have come under increasing fire under the FCPA as inconsistent with the totality of US policy on anticorruption.

New FTC portal to assist businesses in complying with privacy and security laws in the Office of Inadequate Security

The Federal Trade Commission has a new Business Center at that gives business owners, attorneys, and marketing professionals the tools they need to understand and comply with the consumer protection laws, rules, and guides the FTC enforces.

The Facade of FCPA Enforcement by Mike Koehler in FCPA Professor

I am pleased to release (here) my paper, “The Facade of FCPA Enforcement,” recently published by Georgetown Journal of International Law.

Joseph Brenner to join SEC as Chief Counsel of Enforcement Div. in Securities Docket

Joseph K. Brenner is joining the SEC as Chief Counsel of the Division of Enforcement. The SEC announced today that Brenner expects to begin his employment with the agency in the next several weeks. Brenner joins the SEC from law firm Wilmer Cutler, where he has been a partner since 1990. At Wilmer, Brenner was Vice Chair of the firm’s Securities Department and a member of its Securities Litigation and Enforcement Practice Group.