Month: September 2014

The theory of “broken windows,” the enforcement approach being pursued by the SEC, is that prosecuting all violations large and small creates deterrence. That comes from a kind of omnipresence, or a cop on the beat impact. In the SEC’s …

The SEC In the Office Fails To Deter Insider Trader Read More »

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This is the third part of an occasional series. The first part is available here, while the second is here. The entire paper will be published by Securities Regulation Law Journal early next year. . The foreign payments cases held …

THE ORIGINS OF THE FCPA: LESSONS FOR EFFECTIVE COMPLIANCE AND ENFORCEMENT — PART THREE Read More »

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