Until recently, neither DOJ nor the SEC have focused their enforcement efforts on the Foreign Corrupt Practices Act (“FCPA”). Although the statutes were passed in 1977 and amended in 1988, for years enforcement did not appear to be a priority, …

The FCPA: The New SEC and DOJ Enforcement Priority – Part 1: Introduction Read More »

Yesterday, another chapter in the Refco saga unfolded as the SEC brought a suit against its former CEO, Phillip R. Bennett, for fraud as well as books and records violations. The suit follows on the heels of Mr. Bennett’s plea …

The Refco Saga Continues With an SEC Enforcement Action Read More »