Kramer Levin Naftalis & Frankel LLP
La loi n° 2016-1691 relative à la transparence, à la lutte contre la corruption et à la modernisation de la vie économique (dite « Sapin II ») est parue au Journal Officiel le 10 décembre 2016.
On 13 February, 2017 the Luxembourg Financial Regulator (Commission de Surveillance du Secteur Financier –CSSF) announced its position in respect of ESMA's opinion by issuing press release n°17/06.
On 31 December, 2016 the State Prosecutor of the Luxembourg Financial Intelligence Unit (Cellule de renseignement financier du Parquet auprès du Tribunal d'Arrondissement de Luxembourg – the CRF)...
Foley & Lardner
Spurring growth in domestic manufacturing through regulatory reform is a key objective of the Trump Administration.
Without fanfare or forewarning, the US Department of Justice released new anti-corruption compliance guidance on February 8, 2017. The eight page document provides rare insight into the government's evaluation of corporate compliance programs.
Cadwalader, Wickersham & Taft LLP
The SEC Division of Investment Management (the "Division") updated guidance on automated advisers (or "robo-advisors") that provide services directly to clients over the internet.
On February 8, 2017, the United States Department of Justice ("DOJ") Fraud Section published a blueprint for assessing corporate compliance efforts, titled "Evaluation of Corporate Compliance Programs"...
Morrison & Foerster LLP
OCIE also provided examples of the types of deficiencies they see within each compliance topic.
Shearman & Sterling LLP
In January 2017, we published our bi-annual Recent Trends and Patterns in FCPA Enforcement report, part of our FCPA Digest, which provides an analysis of recent enforcement trends and patterns...
Holland & Knight
With year-end FEC filings now submitted and the 2018 election season already underway, federal PAC managers now have the opportunity to reassess efforts to ensuring continuing compliance with federal campaign finance laws.
Morrison & Foerster LLP
In order to provide an overview for busy in-house counsel and compliance professionals, we summarize below some of the most important international anti-corruption developments from the past month, with links to primary resources.
Akin Gump Strauss Hauer & Feld LLP
The DOJ's enforcement action does not allege that Sands paid any bribes in violation of the FCPA, but that Sands failed to maintain an adequate system of internal accounting controls under the FCPA.
In 2016, a year after the sharp decrease in both the number and size of corporate FCPA resolutions, the DOJ's and SEC's enforcement activity rebounded, as reflected by a record number of corporate FCPA resolutions...
Arnold & Porter Kaye Scholer LLP
Trading firms in the United Kingdom and elsewhere outside the United States should continue to monitor ongoing efforts by U.S. regulators to assert long-arm jurisdiction over their trading activities.