Revisiting the Definition of ‘Declinations’
In a recent post, the FCPA Professor questioned the broad application of the label “declination” to any instance of FCPA scrutiny that does not result in an FCPA enforcement action.
In a recent post, the FCPA Professor questioned the broad application of the label “declination” to any instance of FCPA scrutiny that does not result in an FCPA enforcement action.
Tantalum, courtesy of Enough Project via YouTubeThe federal appeals court for the D.C. circuit issued its opinion Monday in National Association of Manufacturers (NAM), et al., v. Securities and Exchange Commission that partially struck down the SEC’s conflict minerals disclosure rule.
During the third quarter, we counted Foreign Corrupt Practices Act enforcement actions involving nine individuals and five corporations. Among the developments: Three FCPA-related trials were completed, all ending badly for the defendants (Bourke, Jefferson and Green). For the first time, the SEC asserted control-person liability in an FCPA case (Faggioli and Huff). And the Justice […]
This year the SEC has already awarded $114 million to whistleblowers, nearly twice the amount than for all of 2019. Three awards in 2020 are among the ten biggest SEC payouts ever, including last week’s $50 million award to a former BNY Mellon currency trader. Would-be SEC whistleblowers and their lawyers should be tingling with […]