Routine SEC Examination Can Lead To FCPA Charge

A routine SEC examination led to FCPA indictments of the managing partner and two employees of U.S. broker-dealer Direct Access Partners (DAP), along with a Venezuelan official who was receiving kickbacks. According to a recent client alert, this should be a wake-up call to regulated businesses in the financial services center and an incentive to meticulous compliance. The routine inquiry can morph into a Federal Corrupt Practices Act investigation, no whistleblower required.