Header graphic for print
Cady Bar the Door Insight & Commentary on SEC Enforcement Actions and Related Issues

Monthly Archives: January 2013

SEC Charges Indian Firms with Acting as Unregistered Broker-Dealers

Posted in Broker-Dealers, Non-scienter-based Violations

On November 27th, the SEC charged four Indian financial services firms with acting as unregistered broker-dealers in the United States.  The firms were accused of providing brokerage services to institutional investors in the U.S. without registering with the SEC as required by Section 15(a) of the Exchange Act.  The SEC censured the firms, who paid… Continue Reading

A Profile That’s Not about Nothing

Posted in Uncategorized

Do you know what Jerry Seinfeld has been doing for the last fifteen years, since his eponymous sitcom went off the air in 1998?  My daughters are big fans of Bee Movie, so I knew he starred in that and was sort of aware that he wrote or produced it several years ago.  And he’s… Continue Reading

SEC Charges Allianz with FCPA Violations

Posted in FCPA, Non-scienter-based Violations, Whistleblowers

On December 17th, the SEC brought a settled administrative FCPA action against Allianz SE, a German insurance company with a subsidiary in Indonesia.  The order does not allege violations of the FCPA’s antibribery provisions, but does claim violations of its books-and-records and internal controls provisions. As the summary in the SEC’s order says, the proceedings… Continue Reading