This paper aims to analyze the March 6, 2019 enforcement advisory in which the Division of Enforcement (Division) of the US Commodity Futures Trading Commission (CFTC or…
This paper aims to analyze the March 6, 2019 enforcement advisory in which the Division of Enforcement (Division) of the US Commodity Futures Trading Commission (CFTC or Commission) announced that it will work alongside the US Department of Justice (DOJ) and other agencies to investigate foreign bribery and corruption relating to commodities markets.
This paper explains the enforcement advisory and outlines key considerations for industry participants and their compliance teams, including the CFTC’s plan to investigate in parallel with other enforcement authorities, an expansion of the CFTC’s existing self-reporting, cooperation and remediation policy to address foreign corruption and the CFTC’s focus on market and economic integrity, and provides guidelines for commodities companies concerning anti-corruption compliance and training programs, investigating potential incidents of bribery and corruption, reporting obligations under the Commodity Exchange Act (CEA) and CFTC regulations, voluntary reporting of incidents of foreign corruption and whistleblowing.
The CFTC announcement adds a new dimension to an already crowded and complex landscape for anti-corruption enforcement. A range of industries, including energy, agriculture, metals, financial services, cryptocurrencies and beyond, must now consider the CFTC and the CEA when assessing global compliance and enforcement risks relating to bribery and corruption.
Expert guidance from lawyers with broad experience in white collar defense, investigations, financial services, securities, commodities, energy and derivatives.
The purpose of this article is to explain recent enforcement trends under the Foreign Corrupt Practices Act (FCPA), providing examples of recent cases.
The paper describes recent trends in FCPA enforcement, including increased enforcement by US authorities, greater vigilance by private industry, and global anti‐corruption efforts. It provides an overview of the FCPA, including the original reason why the Act was passed, its anti‐bribery provisions, the need to show corrupt intent, the interstate commerce requirement, exceptions and affirmative defenses, record‐keeping and control provisions, and penalties. It describes recent FCPA prosecutions and enforcement actions and draws conclusions on how to reduce FCPA risk.
The FCPA is a Watergate‐era law that was passed in response to disclosures by a number of large US corporations that they had made illicit payments to foreign government officials. The FCPA applies to bribes by any US issuer or domestic concern, paid to any foreign official, foreign political party, official or candidate, or official of a public international organization in order to assist in obtaining, retaining, or directing business. To prosecute, the government must show corrupt intent. The FCPA also contains provisions that require accurate record‐keeping and internal controls of US issuers. Violations of the FCPA are subject to both criminal and civil penalties.
The paper presents a thorough explanation, practical advice, and examples of recent violations and penalties by experienced lawyers specializing in FCPA compliance as well as white‐collar defense, securities regulatory matters, internal investigations, and anti‐money laundering.
Up until the turn of the millennium, there had been very little positive representation of women and women in action characters in the action film genre. Two notable…
Up until the turn of the millennium, there had been very little positive representation of women and women in action characters in the action film genre. Two notable exceptions were Ellen Ripley in the Alien movies and Sarah Connor in the Terminator franchise. Whilst this has certainly changed over the last 20 years, one action/horror/science fiction heroine remains neglected: Project Alice in the six Resident Evil films. Portrayed by Milla Jovovich, and loosely based on the platform game character, Project Alice is strong, driven, motivated and tough. This chapter will, through detailed analysis of character, her physical presence through the clothing she wears, psychogeographical aspects, her use of weapons and narrative arc, clearly demonstrate the importance of Project Alice to the horror genre.
Whether poet, novelist, or essayist, a writer is influenced by his past — his family, associates, and the places where he has lived. In English literature even if we limit…
Whether poet, novelist, or essayist, a writer is influenced by his past — his family, associates, and the places where he has lived. In English literature even if we limit ourselves to the standard texts of English literature classes, we can see that England's geography has had an enormous impact on the country's writers, helping them give “to airy nothing/A local habitation and a name.” Consider Chaucer's Canterbury Tales, Wordsworth's “Lines Composed a Few Miles above Tintern Abbey” and “Composed upon Westminster Bridge,” and Jane Austen's use of Bath in Persuasion.
The ACEI (Association for Childhood Education International) in its five year interval Bibliography of Books For Children includes a spearate section on reference books…
The ACEI (Association for Childhood Education International) in its five year interval Bibliography of Books For Children includes a spearate section on reference books for children. One aspect of this section is a presentation of the “State of the Art” as far as reference materials for elementary school age children are concerned. Textbooks on literature for children also include a lesser narrative and bibliographic section on reference books for elementary‐age children. Recent publications such as Carolyn Sue Peterson's give book‐length multi‐page descriptions of optimum reference book collections for elementary grade schools, junior high schools and high schools. No one of these attempts to say categorically that the state of the art of reference materials for children and young adults is at this stage progressing historically from few reference books for children to a late twentieth century plethora of richness and complexity. Peterson gives dates of the initial editions of many works and states that there are many gaps in the areas covered by reference books printed for children and young people.
This chapter explores the role that birdwatching plays in The Archers. It demonstrates some significant similarities between the way that birdwatching is portrayed in…
This chapter explores the role that birdwatching plays in The Archers. It demonstrates some significant similarities between the way that birdwatching is portrayed in present-day Ambridge, and the way it was presented in both fictional and non-fictional literature of the 1940s. These similarities suggest that birdwatching in Ambridge is an activity that tends to perpetuate traditional class and gender divisions. Particularly in terms of gender, this is a surprising discovery, given the many strong female characters in the show, and suggests that cultural assumptions about gender and birdwatching run deep in UK society today. The chapter warns that a failure to recognise these assumptions not only hampers the progress of women who aspire to be taken seriously as ornithologists, but also risks reinforcing dualistic thinking about humans and nature at a time when the environmental crisis makes it more important than ever to recognise the ecological interconnectedness of human and nonhuman worlds. However, the recent development of Kirsty Miller’s storyline, in which she is rediscovering her earlier love of the natural world, not only offers hope of a shift away from this traditional bias but also opens a space for a more nuanced examination of the importance of birds in human–nature relations.
International educational research has shown that high quality coaching, mentoring, and induction for beginning teachers can enhance development and retention of highly…
International educational research has shown that high quality coaching, mentoring, and induction for beginning teachers can enhance development and retention of highly effective teachers and, ultimately, increase student success. In Canada, like many jurisdictions, teacher induction programs have grown in popularity as a means to support beginning teachers, yet programs vary greatly in terms of delivery and effectiveness. This chapter presents the findings from a qualitative case study that examined one bespoke teacher induction program in the Western Québec School Board (WQSB). Specifically, it reports on the experience of mentor–coaches (MC) who are part of the school district’s Mentoring and Coaching Fellowship (MCF). In the district, mentoring and coaching are viewed as distinct, yet interconnected components of an effective induction program. In the WQSB, teaching fellows and MCs learn together in a social and situated context (Lave & Wenger, 1991) as they focus on four key elements: the practice of teaching, navigating school and district culture, what it means to be a teacher, and the formation of a teaching identity. Research has shown effective coaching and mentoring programs not only enhance teaching and learning, but also they offer powerful benefits to veteran teachers. With mentoring and coaching practice highly diverse and inconsistent depending on the quality of the relationship and the context, it is clear that effective selection, support and professional learning and development for MCs is essential. This chapter examines the strengths and challenges of the school district’s Mentor–Coach Professional Learning Network (MC PLN) from the perspective of network members. Data collected from questionnaires, focus groups and semi-structured interviews were abductively analyzed with and against Brown and Poortman’s (2018) five supporting conditions for effective PLNs. Study findings indicated that the MC PLN offers valuable professional learning and development for participants and is a critical feature in a powerful induction program that also focuses on “growing the top.” However, challenges also emerged that highlight the need for the district to ensure ongoing attention to the PLN’s structure and processes in order to sustain MC motivation, engagement, and commitment.
ANOTHER Annual Meeting has come and gone. It was scarcely to be expected that the meeting at Bradford would be a record in the number of members attending, seeing that it is only three years ago since the Association met in the neighbouring city of Leeds, and that Bradford cannot boast either the historical associations or the architectural and scenic setting of many other towns. For the most part therefore the members who did attend, attended because they were interested in the serious rather than the entertainment or excursion side of the gathering, which was so far perhaps to the advantage of the meetings and discussions. Nevertheless, the actual number of those present—about two hundred—was quite satisfactory, and none, we are assured, even if the local functions were the main or an equal element of attraction, could possibly have regretted their visit to the metropolis of the worsted trade. Fortunately the weather was all that could be desired, and under the bright sunshine Bradford looked its best, many members, who expected doubtless to find a grey, depressing city of factories, being pleasingly disappointed with the fine views and width of open and green country quite close at hand.