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In-House Counsel Sanctioned for Failing to Monitor the Preservation of Electronic Evidence

In the Swofford v. Eslinger case, the court sanctioned in-house counsel (but not outside counsel) for failure to preserve evidence. The attorney sanctioned was general counsel for a government entity, the Seminal County Sheriff’s Department. What was unique about this case was that the sanctions were brought against in-house counsel for spoliation of evidence even […]

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Christmas tree in Faneuil hall in boston

Merry Christmas

I’m taking a few days off for the holiday weekend. Image by Das Nili in Wikimedia: Christmas tree near the Quincy Market.jpg

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The Twelve Days of Compliance

Sing it with me: On the first day of compliance, my audit gave to me: Madoff in a prison jumpsuit. . . On the second day of compliance, my audit gave to me: Two legal frauds, and Madoff in a prison jumpsuit. . On the third day of compliance, my audit gave to me: Three […]

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Social Networking is Serious Business

If you live in the Greater Boston area and have $45 lying around, I am speaking on social networking on January 15, 2010 hosted by the New England Chapter of AIIM. Social Networking is Serious Business Newton Marriott Hotel January 15, 2010 8:30 a.m. – 11 a.m. $40 AIIM NE members/$45 non-members I will be […]

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COBRA Subsisdy Set to be Extended

With the COBRA subsidy having expired, Congress has moved ahead to extend the subsidy. Section 1010 of the Department of Defense Appropriations Act, 2010 extends the COBRA subsidy program for six more months, moving from a nine month subsidy to a 15 month subsidy. It also extends the eligibility for workers from December 31, 2009 […]

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Who Said Government Ethics Wasn’t Funny?

You might think that the United States Office of Government Ethics would be overly serious and lack a sense of humor. You would be wrong. Check out the poem at the end of their Reminder about Holiday Gifts & Fundraising (.pdf) The holiday season – a time for good cheer! For egg nog, for parties, […]

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Compliance Bits and Pieces for December 18

Here are some interesting stories from the past week: “Mr. Ruehle, You Are a Free Man”: Judge Carney’s Dramatic Dismissal of the Broadcom Backdating Criminal Case by Kevin M. LaCroix in The D&O Diary There has been widespread news coverage of the dramatic December 15, 2009 decision of Central District of California Judge Cormac Carney to […]

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Credit Suisse Settles OFAC Charges for $536 million

The Credit Suisse Group has reached a settlement with U.S. authorities related to U.S. dollar payments involving parties subject to U.S. sanctions. The $536 million global settlement with Credit Suisse represents by far the largest sanctions settlement in the history of US Treasury’s Office of Foreign Assets Control. The settlement arises out of Credit Suisse’s […]

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SEC Approves New Custody Rule

The Securities and Exchange Commission adopted the proposed Custody Rule for investment advisers originally proposed last May. (See: SEC Releases Proposed Custody Rules for Investment Advisers) As is typical with the SEC, they announced the rule was approved before they made the final version of rule available. The rule amendments will be effective 60 days […]

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November 1, 1974 - "We're Moving Right Along," Herblock, Copyright by The Herb Block Foundation

SEC Historical Society

The Securities and Exchange Commission Historical Society has launched a new gallery exploring the SEC during the mid to late 1970s: In the Midst of Revolution: The SEC, 1973-1981. “From 1973 to 1981, the securities industry and the SEC experienced revolutionary change that created enormous upheaval, provided new economic opportunity and made the task of […]

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