Foreign Corrupt Practices Act
Foreign Corrupt Practices Act enforcement in Financial & Capital Markets sits squarely under the jurisdiction of the U.S. Securities and Exchange Commission and the U.S. Department of Justice, both of which have sustained FCPA action against broker-dealers, asset managers, and financial intermediaries for conduct ranging from improper payments to foreign officials to failures in third-party due diligence. The SEC's 2020 Resource Guide update and the DOJ's Corporate Enforcement Policy both set specific expectations around self-disclosure and compliance program adequacy that financial institutions cannot treat as background reading.
Watch
- DOJ Corporate Enforcement Policy: self-disclosure credit terms and how they apply to financial intermediaries
- Third-party payment controls: regulators are scrutinizing finder and referral arrangements with foreign state-linked entities
- SEC disgorgement authority post-Liu v. SEC: how clawback calculations are being applied in FCPA settlements
- Correspondent banking relationships flagged as FCPA vectors in recent DOJ declination letters
- Anti-corruption compliance program adequacy: DOJ's specific hallmarks checklist for broker-dealer contexts
Recent material activity in Financial & Capital Markets
A selection of recent published briefs; this is not a complete archive.
Federal Reserve proposes dual regulatory framework for payment stablecoin issuers under the GENIUS Act
The Federal Reserve Board released two proposals on September 24, 2026 to establish a supervisory framework for payment stablecoin issuers it oversees under the GENIUS Act. The proposals address reserve backing requireme…
Read a full sample brief →CFTC staff updates crypto FAQ guidance on tokenized customer fund investments and blockchain recordkeeping
Three CFTC divisions released updated FAQs on September 24, 2026, covering tokenized forms of permitted customer fund investments and blockchain-based recordkeeping for registrants. The update extends interpretive positi…
Read a full sample brief →Federal Reserve issues consent prohibition against former Sandy Spring Bank employee for embezzlement
On September 24, 2026, the Federal Reserve Board issued a consent prohibition order against Renee Nicole Brown, a former Sandy Spring Bank employee, for embezzlement. The order bars Brown from participating in the affair…
Read a full sample brief →NYSE National files immediately effective rule change amending clearly erroneous execution standards under Rule 7.10
NYSE National, Inc. filed a proposed rule change with the SEC on September 24, 2026, effective immediately upon filing, to amend Rule 7.10, which governs clearly erroneous execution determinations. The amendment adjusts …
Read a full sample brief →NYSE Texas amends clearly erroneous execution rule with immediate effectiveness
NYSE Texas, Inc. has amended its clearly erroneous executions rule, effective immediately upon filing. The amendment updates the procedures under which the exchange may review and nullify trades determined to be clearly …
Read a full sample brief →Texas Stock Exchange files immediate-effectiveness rule change modifying order processing during regulatory halts and auction mechanics
The SEC published a TXSE proposed rule change on September 24, 2026, effective upon filing. The rule modifies order handling during regulatory halts and adjusts mechanics for IPO auctions, halt auctions, and volatility c…
Read a full sample brief →SEC extends review period for Cboe proposed rule on stop-limit complex orders and stop complex order auctions
The SEC designated an extended review period on September 24, 2026 for a Cboe Exchange proposed rule change. The proposal would accommodate stop-limit complex orders and establish stop complex order auctions as a new auc…
Read a full sample brief →BaFin suspects BERLIN LIVING AG is publicly offering a bond without the required securities information sheet
BaFin suspects BERLIN LIVING AG of offering the "BERLIN LIVING 1 Anleihe 2026/2031" bond to the public in Germany without the legally required securities information sheet. The agency published a consumer notice to this …
Read a full sample brief →EBA submits MiCA review priorities to the European Commission, targeting gaps in crypto-asset regulation
The EBA published its response on September 24, 2026 to the European Commission's targeted consultation on the review of the Markets in Crypto-assets Regulation. The response identifies specific regulatory gaps the EBA r…
Read a full sample brief →Australia ASIC Securities & Investments release pending Cresthaven Analytics full analysis: 26-227MR Former financial services provider employee Emre Basar charged with misappropriation of client funds after ASIC investigation
Australia ASIC Securities & Investments published a regulatory release titled '26-227MR Former financial services provider employee Emre Basar charged with misappropriation of client funds after ASIC investigation'. Cres…
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