Sonnenschein's White Collar & Government Investigations group relies upon its vast experience to offer sound advice and counsel to clients who seek to implement or update compliance programs, ranging from records retention policies to compliance policies mandated under the Foreign Corrupt Practices Act (FCPA) and the federal securities laws, including the Securities Act of 1933, the Securities Exchange Act of 1934, the Investment Advisors Act of 1940, the Investment Company Act of 1940 and the Sarbanes-Oxley Act, as well as under state securities laws.
Our experience in this area allows for invaluable insight when reviewing federal sentencing guidelines for corporations, which reward organizations that develop and implement effective programs for deterring and detecting employee misconduct. In working with corporate clients, the group has stressed the importance of such programs in preventing employee negligence and misconduct that directly victimizes the corporation or gives rise to civil or criminal liability.
Select experience in corporate compliance issues includes:
- Developed and upgraded the codes of business conduct or internal compliance programs for numerous corporations.
- Represented a major multinational stock exchange in drafting its record retention policies and obtaining approval of such policies from the SEC under the Securities Exchange Act of 1934.
- Representing a leading SEC-registered investment advisor in developing a compliance manual and compliance procedures meeting the requirements of the Investment Advisors Act of 1940.
- Representing several public companies in producing a “code of ethics” in compliance with the Sarbanes-Oxley Act.
- Advising one of the country’s leading SEC registered clearing houses in developing a compliance program complying with the federal securities laws, the Export Administration Act of 1979, the Bank Protection Act and Federal Reserve Board guidelines.
- Advising numerous banks in developing compliance programs meeting the requirements of state and federal banking regulators.
