In 1977, Congress enacted the Foreign Corrupt Practices Act as part of the 1934 Securities Exchange Act . The FCPA criminalized the bribery of foreign officials by U.S. corporations and individuals pursuing business in other countries and required that companies with publicly-traded stock meet certain standards regarding their accounting practices, books and records, and internal […]
The Office of Foreign Assets Control in the Treasury Department keeps the Specially Designated Nationals List (SDN). The Specially Designated Nationals List is a publication of OFAC which lists individuals and organizations with whom United States citizens and permanent residents are prohibited from doing business.
According to the Wall Street Journal’s Law Blog, And the FCPA Party Continues: “U.S. government had open investigations into 84 companies at the end of last year, up from three in 2002, according to Shearman & Sterling. “In the 30-plus years I have followed these matters, there were long periods of little activity and few […]
Governor Patrick signed Executive Order 504 an order regarding the the Security and Confidentiality of Personal Information on September 19, 2008. This order revokes the earlier Executive Order 412. There are also new state regulations 201 CMR 17.00: Standards for The Protection of Personal Information of Residents of the Commonwealth (effective Jan. 1, 2009) implementing […]
The Financial Crimes Enforcement Network published the Money Services Business Guide to Money Laundering Prevention (pdf). The manual starts with the definition of a “Money Service Business.” Your business may be an MSB (Money Services Business) if… The business offers one or more of the following services: ■ money orders ■ traveler’s checks ■ check […]
The United States Department of Justice has put together a Lay Person’s Guide to FCPA on the the Department’s site on the Foreign Corrupt Practices Act. The 1988 Trade Act directed the Attorney General to provide guidance concerning the Department of Justice’s enforcement policy with respect to the Foreign Corrupt Practices Act of 1977 (“FCPA”), […]
Kay v. United States (Docket: 07-1281) is on the docket of the Supreme Court’s opening conference on September 29, 2008 for the Court’s October 2008 term. The petition for certiorari and all cert-stage briefs are available at scotusblog.com. David Kay and Douglas Murphy were sentenced in 2005 to 37 and 63 months in prison respectively […]
This post was originally published in my old blog: KM Space. Versions of this article appeared as Which Route? KM Legal, Volume 2 Issue 4, June 2008 http://www.kmlegalmag.com/coverfeature EI Case study: Wiki versus DMS at Goodwin Procter Inside Knowledge, Volume 11 Issue 8 http://www.ikmagazine.com/ The document management system has long been the factory assembly line […]
If you’ve come to this post, you are probably wondering how long I have been blogging and what I’m all about. I first started blogging in February of 2007 with my blog on Knowledge Management: KM Space. It started as an exploration of how blogging and other web 2.0 tools could be used inside a […]
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