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 approves Peoples Bancorp merger with Citizens National Corporation and Citizens Bank of Kentucky
The Federal Reserve Board approved Peoples Bancorp Inc. of Marietta, Ohio, to merge with Citizens National Corporation and indirectly acquire Citizens Bank of Kentucky, Inc., both of Paintsville, Kentucky. The approval a…
Read a full sample brief →NYSE files immediate-effectiveness rule change amending Rule 7.18 governing Disaster Recovery trading sessions
NYSE filed a proposed rule change on September 25, 2026 to amend Rule 7.18, which governs the exchange's Disaster Recovery trading facility and session procedures. The filing took effect immediately upon submission under…
Read a full sample brief →CFTC files $950 million fraud complaint against Cash FX Group and four co-defendants over Ponzi scheme
The CFTC filed a federal complaint on September 25, 2026 against Cash FX Group S.A., its CEO, and three co-defendants for operating a multilevel marketing Ponzi scheme. The complaint alleges fraudulent solicitation of ov…
Read a full sample brief →FDIC releases August 2026 enforcement actions covering nine orders against banks and individuals
The FDIC published its August 2026 enforcement action list on September 25, 2026, comprising nine orders: two consent orders, one amended consent order, one order terminating a consent order, four orders of prohibition, …
Read a full sample brief →NYSE Texas files immediately effective rule change amending Article 6, Rule 13 order-handling provisions
The SEC granted immediate effectiveness to a NYSE Texas proposed rule change on September 25, 2026, amending Article 6, Rule 13. The filing modifies order-handling rules without a standard comment period. This procedura…
Read a full sample brief →NYSE National files immediately effective rule change amending equity trading membership standards under Rule 2.1210
NYSE National's amendment to Rule 2.1210 took effect immediately on September 25, 2026, bypassing the standard comment period under the self-regulatory organization immediate-effectiveness procedure. The SEC received and…
Read a full sample brief →NYSE files immediately effective rule change amending NYSE Rule 1210 governing registered representative qualifications
NYSE filed a proposed amendment to Rule 1210 on September 25, 2026, altering registration and qualification requirements for associated persons. The filing took immediate effect upon submission, bypassing the standard 19…
Read a full sample brief →NYSE American files immediately effective rule change amending equity options margin rule 2.1210
NYSE American LLC filed a proposed rule change on September 25, 2026, amending Rule 2.1210, which governs margin requirements for equity options positions. The filing took effect immediately upon submission under the sel…
Read a full sample brief →NYSE Arca amends options fee schedule to modify Broker QCC Credit and Manual Billable Rebate Program
NYSE Arca has filed a proposed rule change, effective immediately upon filing, to amend its options fee schedule. The amendment modifies both the Broker Qualified Contingent Cross Credit and the Manual Billable Rebate Pr…
Read a full sample brief →NYSE Arca files immediately effective rule change amending equity trading Rule 2.1210
NYSE Arca filed a proposed rule change to amend Rule 2.1210, published in the Federal Register on September 25, 2026. The filing took effect immediately under the self-regulatory organization immediate-effectiveness proc…
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