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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.
It is now forty years since there appeared H. R. Plomer's first volume Dictionary of the booksellers and printers who were at work in England, Scotland and Ireland from…
It is now forty years since there appeared H. R. Plomer's first volume Dictionary of the booksellers and printers who were at work in England, Scotland and Ireland from 1641 to 1667. This has been followed by additional Bibliographical Society publications covering similarly the years up to 1775. From the short sketches given in this series, indicating changes of imprint and type of work undertaken, scholars working with English books issued before the closing years of the eighteenth century have had great assistance in dating the undated and in determining the colour and calibre of any work before it is consulted.
The Royal African Company, the Hudson’s Bay Company, and the East India Company used both owned and hired ships in their seventeenth and eighteenth century trading…
The Royal African Company, the Hudson’s Bay Company, and the East India Company used both owned and hired ships in their seventeenth and eighteenth century trading operations. Why such critical assets were sometimes owned and sometimes rented is explored. Contrary to economic reasoning, ship rentals occurred in shipping markets that were uncompetitive. The use of hired ships was correlated instead to market power in the companies’ selling or output markets. The pattern of ship ownership can be attributed to the close social proximity of shipowners to decision-makers in the companies. By modeling the input hiring decision while allowing for variation in the competitiveness of output markets, it is argued that rent-seeking behavior on the part of company insiders may explain the ownership patterns.
The present study attempted to replicate the findings of Kolb's research identifying two groups of mediators, which she labeled “Dealmakers” and “Orchestrators.”…
The present study attempted to replicate the findings of Kolb's research identifying two groups of mediators, which she labeled “Dealmakers” and “Orchestrators.” Seventy‐seven mediators were presented with a written dispute and asked to react the likelihood that they would use each of nine different mediation techniques. The techniques corresponded to Sheppard's taxonomy of Process Control, Content Control, and Motivational Control techniques. They also rated the perceived effectiveness of each of these three types of control with the dispute. Based upon their responses, the mediators were separated into groups using average‐link cluster analysis. The results suggested four clusters: Cluster 1 members corresponded to Kolb's “Dealmakers,” relying upon Process, Content, and Motivational Control techniques. Cluster 2 members did not correspond to either of Kolb's classifications, choosing to use Content and Motivational Control strategies. Cluster 3 members were similar to Kolb's “Orchestrators;” members of this cluster relied upon Process and Content Control techniques only. Cluster 4 members were reluctant to use any of the control strategies. These findings suggest a partial replication and extension of Kolb's initial work. Implications for future research are discussed.
THOMAS Carlyle's personal crusade for the opening of a lending library in London and his enlisting for the support of that cause influential and wealthy patrons such as…
THOMAS Carlyle's personal crusade for the opening of a lending library in London and his enlisting for the support of that cause influential and wealthy patrons such as Lord Clarendon, Bulwer‐Lytton, Lord Lyttelton, Dean Milman, Lord Houghton, W. E. Gladstone, Sir G. Cornewall Lewis, Henry Hallam—amongst a host of other now forgotten early Victorian luminaries—is well documented. According to Robert Harrison's Preface to the 1888 fifth edition of the Catalogue of the London Library, it opened on 3 May 1841 “with a collection of about 3,000 volumes, which, by the following March, when the first Catalogue was published, had increased to 13,000” (p.viii). The Library was declared formally open on 24 May 1841 using a hired hall in Pall Mall. There were 500 members. In April 1845 the Library moved to its present location in St. James's Square.
The library situation in Great Britain in the 1890s is reviewed.The growth of public libraries is demonstrated and the careers ofnotable librarians such as James Duff…
The library situation in Great Britain in the 1890s is reviewed. The growth of public libraries is demonstrated and the careers of notable librarians such as James Duff Brown outlined. The foundation of the Library Association and Library Assistants Association is noted as is the establishment of the library press. Developments in sub‐scription and academic libraries and the rise of technical education are reviewed.
Although small and medium sized enterprises (SMEs) account for a significant portion of international trade, little is known about the role of strategic orientation…
Although small and medium sized enterprises (SMEs) account for a significant portion of international trade, little is known about the role of strategic orientation culture in improving their foreign launch success. Three orientations – market, entrepreneurial, and learning are all related to organizational learning priorities and reflect a higher order dynamic capability (DC), proactive learning culture (PLC). The authors assert that PLC is particularly important to SMEs whose lack of market power and resources render them vulnerable in risky foreign market launch. Marketing program adaptation and local integration are examined as behavioral mediators of the impact of PLC on foreign market launch success. The paper aims to discuss these issues.
The DC framework guides the study. The authors employ a model with a higher order PLC, two mediating behaviors, and firm foreign market launch success to report on an empirical study of US SMEs that operate in foreign markets. The authors used hierarchical regression analysis and extensive post hoc analyses/robustness checks.
Consistent with the DC framework, SMEs’ foreign launch success is driven by higher and lower order behaviors. The impact of the higher order PLC construct was mediated by two lower order behaviors, marketing program adaptation and local integration. Notably, PLC's influence is stronger than the influence of any subset of its one/two/three first order components.
SMEs need to pay attention to an array of organizational learning processes that combine to engender a PLC, which help optimize the deployment of more tangible, lower order behaviors required for foreign launch success.
Introducing PLC as a DC that enables firms to proactively develop market-oriented, innovative capabilities using a knowledge-based approach. The elements of PLC reflect a more complete view of the role of learning in driving the assembly of lower order behaviors in foreign market launch, which requires both a market-oriented approach and the ability to innovate under conditions of uncertainty. While each element of PLC is valuable, the higher level impact of all three facilitates a more effective culture for those firms, which choose to enter new markets.