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“Compliance Officer” / Dad

Compliance Officer Dad

Today is Father’s Day.

With twin 9-year old boys, Father is just one of my titles. Referee and Compliance Officer being the others. As to the later, I guess Co-Compliance Officer along with my wife is the more accurate title (I wonder what the “Compliance 2.0” folks would say about this structure)?

Father’s Day is a chance to reflect and to be sure being a Dad has informed my view of many things including compliance.

When you really think about, compliance and parenting have a lot in common.

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Unable To File Its Annual Report Due In Large Part To An FCPA Investigation, World Acceptance Corp. Stock Drops 12.4%

world accept

World Acceptance Corporation is a South Carolina based consumer finance company operating in 15 U.S. states and Mexico. It is also the parent company of ParaData Financial Systems, a provider of computer software solutions for the consumer finance industry.

Since late April, its stock price has been on a tear.

That ended yesterday as the company’s stock price fell approximately 12.4% upon disclosing that it would be unable to file its annual report due in large part to a Foreign Corrupt Practices Act investigation.

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What Others Are Saying About Kokesh

Soapbox

Previous posts here, here and here concerned the Supreme Court’s recent benchslap of the SEC in Kokesh v. SEC. As previously noted, the Court unanimously held that disgorgement “in the securities-enforcement context is a ‘penalty’ within the meaning of [28 U.S.C.] 2462 and so disgorgement actions must be commenced within five years of the date the claim accrues.”

The case should impact SEC FCPA enforcement against issuers, but that first requires issuers not to roll over and play dead when faced with SEC scrutiny by agreeing to waive or toll statute of limitations.

This post highlights what others are saying about Kokesh.

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The Challenges Of Detection And Prevention

challenge

The recent London Bridge attack in London. The January 2017 shooting at the Fort Lauderdale airport. The June 2016 shooting at an Orlando nightclub.

These recent instances, and several other similar acts of violence, have little in common with alleged Foreign Corrupt Practices Act offenses.

Except there is often a common thread in terms of the challenges of detection and prevention.

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FCPA Flash – A Conversation With Danforth Newcomb & Cynthia Urda Kassis Regarding “Transacting Business During a Corruption Investigation”

FCPA Flash

The FCPA Flash podcast provides in an audio format the same fresh, candid, and informed commentary about the Foreign Corrupt Practices Act and related topics as readers have come to expect from written posts on FCPA Professor.

This FCPA Flash episode is a conversation with Shearman & Sterling attorneys Danforth Newcomb and Cynthia Urda Kassis who recently authored an article titled “Transaction Business During a Corruption Investigation.”

During the podcast, Danforth and Cynthia discuss: (i) the origins of the article; (ii) what makes potential legal liability under the FCPA or similar laws different than potential legal liability under other laws; (iii) the gap between corporate FCPA enforcement and individual FCPA enforcement; and (iv) whether a recent DOJ statement that “FCPA investigations [should] be measured in months, not years” is believable.

FCPA Flash is sponsored by Kroll. Kroll is trusted by companies and compliance officers worldwide to help prevent, detect, and remediate FCPA challenges with scalable, end-to-end compliance solutions: from high-volume third party screening and automated monitoring, to risk-based due diligence, to complex investigations and monitorships.

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