Compliance Bricks and Mortar for December 22

These are some of the compliance stories that recently caught my attention.


American Law Enforcement’s Focus on Cooperation and Self-Reporting by Lee S. Richards

More recently, law enforcement officials, anxious to improve the effectiveness of their programs, have placed even greater emphasis on the need for companies to rush in to disclose problems they have discovered at the earliest possible time. For example, the Department of Justice has recently amended the United States Attorney’s Manual to create a presumption in favor of a declination in FCPA cases where a Company self-reports, but only a maximum 25 percent fine reduction if it does not self-report yet otherwise cooperates fully. U.S. Attorney’s Manual §9-47.120. [More…]


Another ICO Draws a Securities Class Action Lawsuit by Kevin LaCroix in the D&O Diary

On December 13, 2017, an investor who purchased Centra Tech tokens in the Centra ICO filed a securities class action lawsuit in the Southern District of Florida against the company, Sharma, Trapani, and two other Centra Tech officers. A copy of the complaint can be found here. The complaint alleges that the defendants violated sections 12(a)(1) and 15(a) of the Securities Act of 1933 in connection with the ICO “by offering and selling unregistered securities in direct violation of the Securities Act.” The lawsuit purports to be filed on behalf of all investors in the Centra ICO. [More…]


Quick Case of Kickbacks and COI by Matt Kelly in Radical Compliance

You get the picture. The firms had strong policies and certification requirements, and a failure happened because an employee lied. [More…]


Magnitsky Act Compliance is Straightforward, Experts Say by Samuel Rubenfeld

The U.S. Treasury Department on Wednesday released the sanctions regulations for enforcing the Magnitsky Act, which targets Russian human-rights abusers, but sanctions experts say the rules won’t require any new compliance measures. [More…]


For those of you looking for more compliance and Star Wars stories, here are all of Tom Fox’s: