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Entries in princeling (3)


Survey: Despite growing enforcement risks, adoption of compliance programs has stalled

Ernst & Young just issued its 13th Global Fraud Survey. It shows  regulators aggressively pursuing financial fraud and bribery cases, and expressing increasing concern over cyber risks.

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The princeling problem: In search of a legal theory (Part IV, conc.)

After introducing the princeling problem in Part I, developing a two-prong test in Part II, and showing the difficulty in applying that test to JP Morgan in Part III, we’re here considering the possibility that the government is contemplating a reversal of its prior guidance. Such things are momentous and, from a rule of law perspective, fraught; we should pause to carefully think this one through. 

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The princeling problem: In search of a legal theory (Part 3)

In the prior post we distilled a two-prong rule for hiring the relatives of officials, based on the Guidance, opinion releases, and prior cases.  That rule is:

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