Compliance Bricks and Mortar for April 4

These are some of the compliance-related stories that recently caught my attention. Small Banks Look to Sell as Rules Bite by Michael Rappaport in the Wall Street Journal In a period when low interest rates are squeezing small banks, the costs of adhering to new regulations are taking a toll. Executives from at least a […]

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Accredited Investor Verification

When Congress imposed a lifting of the ban on advertisements for private placements, it also imposed a mandate that the fundraiser “take reasonable steps to verify that purchasers of the securities are accredited investors.” The methods for verification were to be determined by the Securities and Exchange Commission. The SEC, to its credit, did not […]

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The SEC Endorses Yelp for Investment Advisers

Investment Advisers and the Securities and Exchange Commission have been struggling with the use of social media. Advisers see it as a way to communicate with clients and potential clients. The SEC sees it as an area ripe for fraud. Both are right. The SEC has stuck fast to rules on advertisements when it comes […]

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The SEC Shows Some Respect for the Working Woman

The Securities and Exchange Commission decided to emphasize that working wives can be a source of material non-public information. The SEC press release highlighted insider trading cases brought against husbands who engaged in insider trading after learning confidential information from their wives. The first case was against Tyrone Hawk. His wife worked at Oracle. Mr. […]

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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 […]

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Bank Fraud is Okay, But not Drugs or Terrorism

I would like to think that many of the bankers involved in illegal money laundering are not actually aware of the full extent of their malfeasance. Maybe they should have done a better job looking at a client when they noticed a red flag. But sometimes you run across a case where the bankers are […]

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Follow-Up Purchase of a Business from a Foreign Official

There are obstacles when trying to buy a business from a foreign official. The Foreign Corrupt Practices Act prohibits giving or offering anything of value to any foreign official with a corrupt intent to assist in obtaining or retaining business. It is not a flat prohibition on business relationships. But all of the recent FCPA […]

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New Lists to Check for Bad Guys

If you conduct business overseas or have foreign investors in your funds, you are checking the various block persons lists to ensure you’re not working with bad guys. (You are checking, right.) The Office of Foreign Assets Control (“OFAC”), of the U.S. Department of the Treasury, has created two new lists: the Foreign Sanctions Evaders List and […]

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Compliance Bricks and Mortar for March 21

Welcome to Spring. These are some of the recent compliance-related stories that recently caught my attention. Two Thoughts about Dewey LeBoeuf and Parallel Proceedings by David Smyth in Cady Bar the Door In a devastating New York Times story over the weekend, James Stewart zeroed in on that last sentence.  Client relations manager?  Who? Apparently it wasn’t […]

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Do Law Firms Need Compliance Programs? Part 2

Earlier this month it was accounting fraud. This week it’s insider trading. Law firms seem to pose the same risks as any other firm. Do as I say; Not as I do. A clerk at a law firm trolled the document management system for information on mergers when the firm was representing one of the […]

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