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FCPA-Related Matter Against Morgan Stanley Allowed To Proceed


In the aftermath of the 2012 Garth Peterson enforcement action (a former managing director for Morgan Stanley’s real estate business in China) and the DOJ’s so-called “declination” of Morgan Stanley, the company seemed to become the darling of the compliance community.

Never mind that the “declination” appeared to be little more than a conveniently timed public relations campaign by the DOJ (see here).  Moreover, according to Peterson, the DOJ was lying about Morgan Stanely’s supposed “wonderful compliance program.” (See here).

As first reported here by Bloomberg, an FCPA-related administrative Sarbanes-Oxley retaliation claim filed by Christopher Garvey (a former in-house lawyer at Morgan Stanley in Hong Kong) recently survived the company’s motion to dismiss.

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