Legg Mason Archives - FCPA Professor

SEC Finally Announces Its FCPA Enforcement Action Against Legg Mason

By Mike Koehler on August 27, 2018 in 2018 Enforcement Actions, Disgorgement, Financial Services Industry, Kokesh, Legg Mason, Libya, SEC Enforcement Action

Prior posts here and here highlighted the DOJ’s June FCPA enforcement action against Legg Mason regarding business conduct in Libya. It was noted in the prior post that FCPA enforcement actions against issuers that involve a DOJ and SEC component are almost always announced on the same day. Yet for some reason, back in June the i’s were not dotted or the t’s crossed at the SEC and the DOJ’s June enforcement action clearly had a placeholder for the forthcoming SEC prong.

That happened earlier today as the SEC finally announced its enforcement action.

Friday Roundup

By Mike Koehler on July 6, 2018 in Agency Issues, Glencore, KBR, Legg Mason, Parent – Subsidiary Issues, Repeat Offenders, Root Causes, Whistleblowers

Scrutiny alert, some responsibility, repeat offender, proposed changes to whistleblower rules, and for the reading stack. It’s all here in the Friday roundup.

Scrutiny Alert

Glencore plc, an Anglo–Swiss mining company with headquarters in Switzerland and ADRs traded on a U.S. exchange recently announced:

Issues To Consider From The Legg Mason Enforcement Action

By Mike Koehler on June 6, 2018 in Books and Records, Disgorgement, Foreign Official, Internal Controls, Kokesh, Legg Mason, Libya, Root Causes, Statute of Limitations

This previous post went in-depth into the DOJ’s recent Foreign Corrupt Practices Act enforcement action against Legg Mason. This post continues the analysis by highlighting additional issues to consider.

SEC Enforcement Action Is Forthcoming

Given Legg Mason’s recent disclosure (see here for the prior post), it was a bit of a surprise that this week’s enforcement action included only a DOJ component. FCPA enforcement actions against issuers that involve a DOJ and SEC component are almost always announced on the same day.

Legg Mason Also Ponies Up $64 Million To Resolve FCPA Enforcement Action Concerning Conduct In Libya That Occurred 9-14 Years Ago By “Only Two Mid-To-Lower Level Employees Of A Subsidiary”

By Mike Koehler on June 4, 2018 in 2018 Enforcement Actions, Anything of Value, DOJ Enforcement Action, Financial Services Industry, ISO 37001, Legg Mason, Libya, Third Parties, Travel and Entertainment, Undercover Investigations

A few hours after the DOJ announced a net $293 million Foreign Corrupt Practices Act enforcement action against Société Générale S.A concerning conduct in Libya that occurred 9-14 years ago (see here for the prior post), the DOJ also announced that investment management firm Legg Mason also agreed to pony up $64 million to resolve a related enforcement action.

Pursuant to a three-year NPA, Legg Mason agreed to pay $64 million based on the conduct of “only two mid-to-lower level employees of a subsidiary of the company” (specifically Permal Group Ltd.). According to the DOJ: “Permal’s financial statements were consolidated into Legg Mason’s financial statements and they participated in a net revenue sharing arrangement, and all employees of Permal were subject to Legg Mason’s code of conduct.”

Friday Roundup

By Mike Koehler on June 1, 2018 in Azat Martirossian, Basil Al Jarah, Dun & Bradstreet, FCPA Related Charges, FCPA Statistics, General Cable Corp., Latin America, Legg Mason, Leighton Holdings, Media Reporting, Media Reporting About the FCPA, Petros Contoguris, Rolls-Royce, Serious Fraud Office, Third Parties, United Kingdom, Vitaly Leshkov, Ziad Akle

Scrutiny alert, novice FCPA commentary matters, additional charges, survey says, across the pond, and for the reading stack. It’s all here in the Friday roundup.

Scrutiny Alert

Some companies disclose Foreign Corrupt Practices Act very early and then update the disclosure for years. Other companies have different disclosure practices. Global asset management firm Legg Mason Inc. (a company that has not previously disclosed FCPA scrutiny) recently disclosed:

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SEC Finally Announces Its FCPA Enforcement Action Against Legg Mason

Friday Roundup

Issues To Consider From The Legg Mason Enforcement Action

Legg Mason Also Ponies Up $64 Million To Resolve FCPA Enforcement Action Concerning Conduct In Libya That Occurred 9-14 Years Ago By “Only Two Mid-To-Lower Level Employees Of A Subsidiary”

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