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
Securities
SEC Investor Advocate Report on Objectives
The Securities and Exchange Commission’s Office of the Investor Advocate recently issued its fiscal year 2025 Report on Objectives. The Report is one of two annual reports required to be filed by the Investor Advocate with the Committee on Banking, Housing, and Urban Affairs of the Senate and the Committee on Financial Services of the…
FINRA Reminds Members of Regulatory Obligations When Using Generative Artificial Intelligence (AI) and Large Language Models
On June 27, 2024, the Financial Industry Regulatory Authority, Inc. (“FINRA”) issued Regulatory Notice 24-09 (the “Notice”) reminding member firms that FINRA’s rules and the securities laws apply to the use of artificial intelligence (“AI”), including large language models and other generative AI (“Gen AI”) technology, just as they apply when member firms use any…
In-House Corner: How We’re (Semi) Embracing AI
By Broc Romanek
This feature of our blog is where our in-house readers share tips, anecdotes and thoughts about things that come up in their daily practice. This particular batch of thoughts is about how in-house practitioners are embracing generative AI so far:
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SEC Charges Founder of AI Hiring Startup Joonko with Fraud
The Securities and Exchange Commission today charged Ilit Raz, CEO and founder of the now-shuttered artificial intelligence recruitment startup Joonko, with defrauding investors of at least $21 million by making false and misleading statements about the…
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8 Things to Know Right Now
By Broc Romanek
Here’s our latest edition of our monthly feature – a quick snapshot of recent developments:
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SEC Director Of Enforcement Grewal On Cooperation
By Mike Koehler
Recently Gurbir Grewal (the SEC’s Director of the Division of Enforcement) delivered this speech titled “The Five Principles of Effective Cooperation in SEC Investigations” at a securities law conference.
This post summarizes the speech and provides factual information and rebuttal points relevant to certain topics.
Grewal began as follows:
“This event … offers regulators like me a…
SEC Investor Advisory Committee to Examine the New Frontier for Investment Advice and Discuss AI Regulation at June 6 Meeting
The Securities and Exchange Commission’s Investor Advisory Committee will hold a virtual public meeting on June 6, 2024, at 10 a.m. ET. The meeting will be webcast on the SEC website. The committee will host two panels: Examining the New…
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Frequently Asked Questions for FINRA Member Firms on AI Use in Public Communications
Several days ago, FINRA released guidance updating its Frequently Asked Questions relating to Rule 2210 on Advertising and Public Communications to address Artificial Intelligence. This follows after FINRA has consistently been noting that the use of AI and AI tools should be addressed by member firms in their policies and procedures and may implicate their…
SEC’s Upcoming Investor Advisory Committee Meeting: Finfluencers and AI
The Securities and Exchange Commission announced an upcoming meeting of its Investor Advisory Committee, which will be held on June 6, 2024. The agenda includes a number of interesting topics.
The Committee will consider and address the impact of “finfluencers.” The agenda notes that recent studies have found that these social media influencers who focus…