Month: October 2011

Disgorgement and the impact of the Fifth Amendment are issues which reoccur in SEC enforcement actions. Circuit Judge Loken, in an opinion concurring in part and dissenting in part, from an order affirming a grant of summary judgment in a …

DISGORGEMENT AND THE FIFTH AMENDMENT IN SEC ACTIONS Read More »

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“Do they get it?” This is a question frequently asked by FCPA enforcement officials. “Do they get it” meaning does the company understand what happened, why it happened and what is required going forward. Does the company “get” the point …

FCPA COMPLIANCE: DOES THE SEC “GET IT?” Read More »

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