On November 19, 2015, the SEC announced a settlement with investment advisory firm Sands Brothers Asset Management, LLC for violating the Custody Rule, SEC Rule 206(4)-2, which requires that registered investment advisers who have custody of their clients’ assets put in place policies and procedures intended to safeguard those assets against loss, misuse or misappropriation.
Pizza has become a staple of the American diet, and employees at nine Papa John’s pizzerias in New York often worked more than forty hours per week in recent years to satisfy their customers’ cravings.
After a two year investigation, the Serious Fraud Office (“SFO”) has found insufficient evidence to prosecute Japanese camera-maker Olympus and its UK subsidiary Gyrus Group relating to an accounting scandal four years ago under English law.
Charlie Sheen disclosed last week on the Today show that he was infected with the AIDS virus.
The SEC announced this week its proposal to substantially overhaul the rules regarding alternative trading systems (“ATS”), often referred to as dark pools.
The U.S. Department of Justice (DOJ) detailed new rules that would focus investigations of corporations on responsible individuals and warned that companies cannot abuse the attorney-client privilege to hide key facts in criminal investigations.
The Washington Post reported last week that the DOJ is considering an internal policy that could give some companies a “free pass” if they voluntarily disclose violations of the FCPA, including information regarding culpable employees.
All five people convicted in the Peanut Corporation of America (PCA) criminal case are now in federal custody.
Given the activity of the Serious Fraud Office (“SFO”) over recent months, we decided to take a look at the SFO’s 2014-2015 annual report published earlier this year, to compare it to recent years.
Second Circuit Upholds Common-Interest Privilege for Borrower’s Sharing of Legal Advice with Consortium of Lenders
The Second Circuit held last week that a borrower did not waive the attorney-client privilege by providing documents to a consortium of lender banks that shared a common legal interest with the borrower in the tax treatment of a refinancing and corporate restructuring resulting from an acquisition originally financed by the consortium.