WPP Enforcement Action: Part 1 – Background

WPP Enforcement Action: Part 1 – Background

We now have our second Foreign Corrupt Practices Act (FCPA) corporate enforcement action in 2021. The Securities and Exchange Commission (SEC) entered into a Cease and Desist Order (Order) last week with WPP plc, the world’s largest advertising group, for the paying...

FCPA Compliance Report-Episode 332, Marc Bohn on the Kokesh Decision

Kokesh v. SEC, the US Supreme Court held the profit disgorgements operate as a penalty under the Securities and Exchange Act of 1934, as amended. As such “any claim for disgorgement in an SEC enforcement action must be commenced within five years of the date the claim...