Month: July 2016

Well designed compliance systems coupled with solid internal controls can be instrumental in preventing violations of the FCPA. Despite best of efforts, there is no doubt that even a well-constructed compliance system can be circumvented. Johnson Controls, a global firm …

Compliance, Cooperation Mitigates FCPA Liability with DOJ-SEC Read More »

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How effective is the SEC enforcement program at deterrence? With the adoption of the “broken windows” theory of enforcement the agency adopted a theory of market policing borrowed from the New York City police department. It is built on the …

Effective SEC Enforcement – Built on Fundamental Fairness Read More »

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