Year: 2017

The books, records and internal control provisions are an integral part of the FCPA. The Commission’s most recent action involving those provisions, however, centers on a claimed internal control failure by a firm when retaining a foreign agent and imposes …

SEC: Firm’s IC Failure Equals Liability For Subsequent Acquirer Read More »

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Questions regarding the validity of SEC ALJs continue to be a key focus for SEC enforcement. The Tenth Circuit concluded that the retention of SEC ALJs violated the Constitution’s Appointment Clause, setting up a potential conflict in the circuits that …

This Week In Securities Litigation (Holiday edition – period from December 23, 2016 to January 6, 2017) Read More »

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