There are three and half bills in Congress for regulating private investment funds. The Hedge Fund Adviser Registration Act of 2009, the Hedge Fund Transparency Act of 2009 and the Private Fund Transparency Act of 2009 are all sitting in committee. The half is the proposal from the Obama administration: Private Fund Investment Advisers Registration … Read more »
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Bits and Pieces on Compliance
Here are a few stories and items that caught my eye recently, but I have not had time to build-out to a full post: Role of Federal Sentencing Guidelines in FCPA Cases from the WrageBlog Given the tremendous fines imposed upon Siemens AG and Kellogg Brown & Root LLC (“KBR”) in the past 10 months, … Read more »
Ruehle Decision on Internal Investigations Overturned
The Ninth Circuit stepped into a conflict between former Broadcom CFO William Ruehle and lawyers at Irell & Manella. The disagreement concerned a type of misunderstanding on whether lawyers during an internal company probe are representing a singular executive or the company itself. At issue was whether Irell clearly explained to Ruehle that it was … Read more »
National Cyber Security Awareness Month
October is National Cyber Security Awareness Month. Check out the top tips to keep you safe online: Know who you’re dealing with online. Keep your web browsers and operating system up to date. Back up important files. Protect your children online. Use security software tools as your first line of defense. Use strong passwords or … Read more »
Fair Value Accounting: What Lawyers Need to Know
Bruce Carton of Securities Docket put together a great panel of securities and accounting experts to discuss the evolution of fair value accounting regulations and the impact of the guidelines in accounting and legal contexts. Presenters Ray Ball, Professor of Accounting, Univ. of Chicago, Booth School of Business Andy Wong, Analysis Group Michael Young, Willkie … Read more »
Opportunities Exist to Improve DOD’s Oversight of Contractor Ethics Programs
The Government Accounting Office released a report on the compliance and ethics programs of 57 government contractors each with yearly contracts over $500 million: Defense Contracting Integrity: Opportunities Exist to Improve DOD’s Oversight of Contractor Ethics Programs The report’s survey was conducted in September 2008, before the new Federal Acquisition Regulations were put in place … Read more »
SEC’s Office of Compliance Inspections and Examinations Gets a Review
The SEC’s Division of Enforcement was not alone in getting a report from the SEC’s Inspector General: Improvements Needed Within the SEC’s Division of Enforcement. The Office of Compliance Inspections and Examinations also got a review from the Inspector General: Review and Analysis of OCIE Examinations of Bernard L. Madoff Investment Securities, LLC. For this … Read more »
Improvements Needed Within the SEC’s Division of Enforcement
The SEC’s Inspector General, H. David Kotz, released his most recent report: Program Improvements Needed Within the SEC’s Division of Enforcement. The report is sort of a follow-up to the Madoff Report. The Office of the Inspector General conducted a review “to identify systemic issues that would prevent Enforcement from accomplishing its mission to enforce … Read more »
Facebook, Twitter, LinkedIn and Compliance: What Are Companies Doing?
The Society of Corporate Compliance and Ethics and the Health Care Compliance Association conducted a survey among compliance and ethics professionals in late August 2009 to see what employers are doing about the use of these sites by their employees. They got back almost 800 responses from their members using an online survey tool. 50% … Read more »