Securities

The Securities and Exchange Commission today announced charges against Rimar Capital USA, Inc. (Rimar USA), Rimar Capital, LLC (Rimar LLC), Itai Liptz, and Clifford Boro for making false and misleading statements about Rimar LLC’s purported use of…

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It is September which means enforcement agency officials hit the “conference circuit” to give scripted speeches.
Last week it was DOJ Principal Deputy Assistant Attorney General Nicole Argentieri delivering a speech to a corporate compliance audience in New York (see here for the prior post), yesterday it was Argentieri delivering a speech to a corporate compliance

The Foreign Corrupt Practices Act has always been a law much broader than its name suggests.
Sure, the FCPA contains anti-bribery provisions which concern foreign bribery.
Sure, the FCPA’s books and records and internal controls provisions can be implicated in foreign bribery schemes.
However, the fact remains that most FCPA enforcement actions (that is enforcement