There have been many stories written about the Goldman Sachs investment in Facebook. On one hand, there is the chatter about the investment placing the valuation at $50 billion. On the other, there hand there is the talk about how this affects a possible IPO by Facebook. There are two main reasons for an public … Read more »
The SEC, Funding, and Rulemaking
There is turmoil in Congress as Republicans take control of the House of Representatives. One of their targets seems to be implementation of the Dodd-Frank Wall Street Reform and Consumer Protection Act. It’s probably too late to repeal it and too early to start amending it. Too much corporate machinery has been put in place … Read more »
Private Equity Portfolio Companies and Bribery Charges
The U.S. is investigating Allianz SE, for possible bribery by a German printing press company in which it holds a majority stake according to a story by Joe Palazzolo in WSJ.com’s Corruption Currents. The Foreign Corrupt Practices Act bars US companies from paying bribes to foreign officials to keep or obtain business. The SEC claims … Read more »

God Says No More Money Laundering
I expect that we will see a see standard in anti-money laundering programs. Pope Benedict XVI committed the Vatican to the fight against money laundering, counterfeiting and the financing of terrorism. The headquarters of the Roman Catholic Church will now meet international standards of financial transparency. He has established a set of internal regulations which … Read more »
Happy New Year
New Year’s Eve is generally a time to reflect on the past and look forward to the future. For many it also involves an excessive amount of alcohol, an expensive dinner in a crowded restaurant, or a long wait for Chinese food delivery. I’m sure there is a compliance story in there somewhere. But I’m … Read more »
“Free” and the Black Swan
I’ve talked in the past about the Black Swan by Taleb and at other times about Free by Chris Anderson. I think I missed a connection between the two. Taleb points out that the Black Swan event is only a surprise to one side. The turkey thinks life is great living on the farm. Until … Read more »
Hedge Fund Hotels and Compliance
The Massachusetts Secretary of the Commonwealth has been investigating hedge fund hotels. Start-up hedge fund managers receive reduced-rent office space in return for send their trading business to the landlord. UBS AG has agreed to pay $100,000 to settle charges that it failed to disclose the relationship. Galvin charged there was a conflict that harmed … Read more »
The London Olympics and the Bribery Act
The London Olympics in 2012 will be a test of strength, agility and endurance. That’s just be for the corporate sponsors trying to comply with the UK’s Bribery Act. Unlike the US Foreign Corrupt Practices Act, the UK’s Bribery Act applies equally to payments made to foreign government officials as it does to payment made … Read more »
Will Cash Incentives for Whistleblowing Undermine Compliance Programs?
Section 922 of the Dodd-Frank Wall Street Reform and Consumer Protection Act provides an expanded whistleblower program that allows the whistleblower to get part of the money paid to the SEC for the violation. After several years of encouraging the development of internal complaint hotlines and compliance programs, Congress seems to now be encouraging a … Read more »
Santa Claus and Corruption
Even Santa Claus may have to face bribery and corruption on journey to deliver presents. What do you do when faced with a border guard demanding something on the side? A funny video take on the issues from Transparency International: For those of you who celebrate it, Merry Christmas. Read more »