SEC’s In-House Courts Are Upheld

There have been several challenges to the constitutionality of the in-house judges at the Securities and Exchange Commission. The problem is that the judges are appointed by an internal panel instead of by the President or the SEC Commissioners. That will not make a difference for Raymond Lucia and his “Buckets of Money.” Radio personality […]

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How To Pay A Bribe

A thick envelope arrived in the mail from Trace International, the firm of anti-bribery compliance experts. The title caught me off guard: How to Pay a Bribe.  I would have thought Trace would be focused on how to stop bribes. Then, of course, I read the subtitle: Thinking Like a Criminal to Thwart Bribery Schemes. It’s […]

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On the Road, On My Bike

I’m not thinking about compliance today. When this story gets posted I’ll be somewhere on the road between Hillsdale, New York and Sturbridge, Massachusetts. I’m with a dozen members of my Pan-Mass Challenge team and a few dozen other hearty souls who have added on a pre-ride we call Day Zero. The first official day […]

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Compliance Bricks and Mortar for August 4

It’s early round up this week. I’m taking Friday off to ride additional day before the Pan-Mass Challenge. In the meantime, these are some of the compliance-related stories that recently caught my attention. People, please stop making these two insider trading-related mistakes! by Bruce Carton in Compliance Week There are two insider trading-related “mistakes” that I have […]

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More Targeting of Real Estate Transactions by FinCEN

The US Financial Crimes Enforcement Network has started to look closely at cash purchases of expensive real estate as a possible source of money laundering. In January, FinCEN issued two Geographic Targeting Orders, one for New York and one for Miami. Now more metropolitan areas are in FinCEN’s sights. According to the press release, FinCEN has been […]

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DLA Piper Takes a Look at Compliance

DLA Piper conducted its first compliance survey. I assume they reached out to some subset of the law firm’s clients seeking responses to the 34 questions. The answers came from not just the biggest companies. Although 38% of the companies had more than 5,000 employees, 20% had 100 or fewer. The companies were split 60/40 […]

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Turning a Slimy Internet Scheme Into Securities Fraud

Charles Scoville wants to help you get better traffic to your website. He does it through the slimy method of paying people to click on an ad for your website. But he added in a revenue sharing system. The SEC decided that the slimy method had turned securities fraud. There are many, many, many platforms […]

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Compliance Bricks and Mortar for July 29

If you enjoy Compliance Building, please join many of my other readers and support my Pan-Mass Challenge ride to fight cancer next week. (Thank you to those who have already donated.) I’m pedaling from the New York border to Provincetown on August 5-7. 100% of your donation goes to the fight against cancer. You can […]

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The Rise of the Professional Whistleblower

With the proliferation of whistleblower regimes at regulatory agencies we should not be surprised that there are professional whistleblowers. The Securities and Exchange Commission gave its blessing earlier this year when it granted a whistleblower award to a company outsider. This week the SEC and the DOJ announced a half billion dollar settlement with State […]

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Rethinking Your SEC Introductory Presentation

I was chatting with a compliance examiner from the Securities and Exchange Commission and heard that the format for private fund exams had changed. Given the complexity and diversity of business models for private funds, the SEC is trying to narrow the scope of its examination. Presumably to help in that effort, the SEC examiners […]

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