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On March 4, 2013, the Office of Compliance Inspections and Examinations ("OCIE") of the Securities and Exchange Commission (the "SEC") issued a Risk Alert identifying "significant deficiencies" in compliance with Rule 206(4)-2 (the...

Today, the U.S. Supreme Court largely closed the door on the federal government’s ability to pursue monetary penalties in civil enforcement actions involving conduct that is more than five years old.  The Court’s decision in Gabelli et al. v....

On November 28, 2012, Federal Reserve Board Governor Daniel Tarullo provided a preliminary glimpse at new requirements to be imposed on non-US banks that have US banking operations.  A proposed rule to be published by the Federal Reserve within weeks will...

Today, the U.S. Department of Justice ("DOJ") and the U.S. Securities and Exchange Commission ("SEC") (collectively, the "Agencies") released "A Resource Guide to the U.S. Foreign Corrupt Practices Act" (the "Guide"). ...

The Office of Compliance Inspections and Examinations (“OCIE”) of the U.S. Securities and Exchange Commission (the “SEC”) announced last month that it would soon begin conducting “presence examinations” of newly registered...

On August 8, 2012, in SEC v. Apuzzo, the United States Court of Appeals for the Second Circuit ruled that the US Securities and Exchange Commission ("SEC") is not required to establish that a defendant proximately or directly caused injury in a securities...

In recent months, two district courts have addressed the issue whether employees who claim they were retaliated against for internally reporting violations of the Foreign Corrupt Practices Act can bring a private civil lawsuit against their former employers under...

On Thursday, April 19, 2012, the Federal Reserve Board issued a policy statement clarifying the manner in which the Volcker Rule prohibitions would apply and would be enforced during the statutory two-year Conformance Period.  Despite public statements by...

  The Jumpstart Our Business Startups Act (the JOBS Act) was signed into law by President Obama on April 5, 2012. The JOBS Act seeks to encourage more initial public offerings in the United States and to facilitate other forms of capital formation by reducing...

On February 15, 2012, the Securities and Exchange Commission (the "Commission") adopted amendments to rule 205-3 under the Investment Advisers Act of 1940 (the "Advisers Act"). The rule amendments alter dollar amount thresholds that determine...