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Doug Cornelius on compliance for private equity real estate

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Compliance Bricks and Mortar – Blizzard Edition

Doug Cornelius January 5, 2018 Compliance Bricks and Mortar   [+]

I’ve just come inside after digging out from yesterday’s blizzard. These are some of the compliance-related stories I’m going to read by the fire. Is Bitcoin Really in a Bubble? in Knowledge@Wharton [T]he cryptocurrency community is divided on whether bitcoin is a “side show or the show.” However, he believes that the “fundamental breakthrough is … Read more »

Start Your Compliance Year Right

Doug Cornelius January 2, 2018 Compliance Programs   [+]

After a long weekend, and perhaps a vacation, compliance professionals are coming back into the office with 2018 on the calendar. It’s a clean slate. The possibilities are endless. Where to start? I don’t have the answer. There is so much to get done and so many challenges ahead. No organization has has the same … Read more »

Holiday Joy

Doug Cornelius December 25, 2017January 5, 2018 Off Topic   [+]

Wishing you joy in this last week of 2017, from my family to yours.   Read more »

Compliance Bricks and Mortar for December 22

Doug Cornelius December 22, 2017 Compliance Bricks and Mortar   [+]

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 … Read more »

compliance politics and money

More Political Contribution Problems

Doug Cornelius December 21, 2017December 21, 2017 Fundraising   [+]

There is too much money in a politics. I understand the Securities and Exchange Commission’s desire to purge political contributions from the investment adviser business for state and local government money. But I’ve never been a fan of Rule 206(4)-5, the pay-to-play rule. It’s continuing to ensnare companies in ways that highlight problems with the rule … Read more »

SEC’s Regulatory Agenda

Doug Cornelius December 20, 2017December 19, 2017 Compliance Programs   [+]

A few months ago, Securities and Exchange Commission Chairman Jay Clayton stated that the SEC had been hard at work on developing its rule-making agenda for the upcoming year. In the coming weeks and months, I expect the SEC’s near-term rulemaking objectives to be fully reflected in our upcoming Regulatory Flexibility Act Agenda. As a … Read more »

The Most Massachusetts Bribe

Doug Cornelius December 19, 2017March 25, 2024 Bribery and Corruption   [+]

One thing that is clear about bribery and corruption is that the payments are not always envelopes full of cash. The FCPA opinions have long pointed out that directing charitable donations to the decision-makers “pet” charity could be a bribe. As former Director of the the Division of Enforcement at the SEC, Andrew Ceresney pointed … Read more »

Compliance Lessons from Star Wars – Man Versus Machine

Doug Cornelius December 15, 2017December 15, 2017 Compliance Programs   [+]

With the release of Episode VIII – The Last Jedi, I’m joining Tom Fox in tying compliance and the Star Wars franchise together in some posts this week. (I saw the movie last night, but I will refrain from revealing anything other than it was terrific.) One of the central themes of the Star Wars franchise is man … Read more »

Compliance Lessons from Star Wars – Rebels

Doug Cornelius December 14, 2017December 14, 2017 What is a Security?   [+]

With the pending release of Episode VIII – The Last Jedi, I’m joining Tom Fox in tying compliance and the Star Wars franchise together in some posts this week. Star Wars is about the rise of the evil galactic empire and the rebels who fight against it. I think some Bitcoin advocates are trying to be the … Read more »

Compliance Lessons From Star Wars – Lies

Doug Cornelius December 13, 2017 Fraud   [+]

With the pending release of Episode VIII – The Last Jedi, I’m joining Tom Fox in tying compliance and the Star Wars franchise together in posts this week. I’ve always been trouble by the lie from Obi Wan Kenobi to Luke Skywalker: “Darth Vader betrayed and murdered your father.” It’s the little lies that lead to bigger lies … Read more »

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