Panel Agenda. Session III(e) Fraud and Misappropriation -- Detecting and Preventing
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1 Panel Agenda Session III(e) Fraud and Misappropriation -- Detecting and Preventing How to comply with anti-fraud laws and regulations Detecting insider trading, market manipulation activities, and rumor mongering When and how to conduct an internal investigation of suspected non-compliance or fraud Whistleblower issues Important components of an effective fraud prevention program James R. Downing JP Morgan Chase Tracy Webb Office of New York State Comptroller Michael Wise Lawrence, Kamin, Saunders & Uhlenhop, L.L.C. I. Things Certified Fraud Examiners (CFE s) Know and You Should Too A. Fraud Triangle (Legal Outline p. 1; Exhibit 1 -- PowerPoint p. 2) B. Characteristics of the Fraudster (p. 3) C. Red Flags for Fraud (p. 4) D. Red Flags/Concerns E. Solutions II. Legal Basis for Fraud (Legal Outline p. 1; Exhibit 1 -- PowerPoint p. 5) A. Exchange Act Rule 10b-5 B. SRO rules C. State securities acts D. Federal and state criminal provisions NSCP National Membership Meeting Washington DC- October 22-24, 2012
2 III. Trends in Recent Fraud Enforcement Actions (Legal Outline p. 2; Exhibit 1 -- PowerPoint p. 6) A. Fraud Enforcement Cases (PowerPoint p. 7; Exhibits 2-5) B. Insider trading, Market Manipulation, Rumor Mongering (Power Point p. 8) C. Selling away/prohibited outside business activity (PowerPoint p. 9) IV. How to Identify Areas of Fraud Risk/Fraud Prevention (Legal Outline p. 2; Exhibit 1 -- PowerPoint p. 10) See Exhibit 6: Common Fraud Patterns and Indicia in Publicized Cases V. Investigating Fraud (Legal Outline p. 3; PowerPoint p. 11) A. Techniques for Investigating Fraud B. When and How to Conduct Internal Investigations (p. 12) C. Ethical Considerations (Legal Outline p. 3; Exhibit 1 -- PowerPoint p. 13) VI. Whistleblower provisions (Legal Outline p. 3) VII. Concluding thoughts E:\MW\NSCP Presentations\Panel Agenda Fraud and Misappropriation doc 2
3 Legal Outline Session III(e) Fraud and Misappropriation -- Detecting and Preventing How to comply with anti-fraud laws and regulations Detecting insider trading, market manipulation activities, and rumor mongering When and how to conduct an internal investigation of suspected non-compliance or fraud Whistleblower issues Important components of an effective fraud prevention program James R. Downing JP Morgan Chase Tracy Webb Office of New York State Comptroller Michael Wise Lawrence, Kamin, Saunders & Uhlenhop, L.L.C. I. Things Certified Fraud Examiners (CFE s) Know and You Should Too A. Fraud Triangle (Exhibit 1 -- PowerPoint p. 2) B. Characteristics of the Fraudster (p. 3) C. Red Flags for Fraud (p. 4) D. Red Flags/Concerns E. Solutions 1. Compliance 2. Internal investigations II. Legal Basis for Fraud (Exhibit 1 -- PowerPoint p. 5) A. Exchange Act Rule 10b-5 B. SRO rules 1. Incorporate federal anti-fraud rules
4 2. Business conduct rules -- just and equitable principles (E.g. FINRA Rules 2010; 2020) C. State securities acts D. Federal and state criminal provisions 1. Mail fraud (18 U.S.C. 1341) 2. Wire fraud (18 U.S.C. 1343) 3. Theft III. Trends in Recent Fraud Enforcement Actions (Exhibit 1 -- PowerPoint p. 6) A. Fraud Enforcement Cases (p. 7) 1. Citigroup (Exhibit 2) 2. Gupta/Rajuratham (Exhibit 3) 3. Brookstone (Exhibit 4) 4. Oxford (Exhibit 5) B. Insider trading, Market Manipulation, Rumor Mongering (p. 8) 1. Typical red flags/surveillance 2. Examples C. Selling away/prohibited outside business activity (p. 9) 1. Typical red flags 2. Examples 3. FINRA Rule 3270 (old NASD Rule 3030); Rule 3040 (private securities transactions) IV. How to Identify Areas of Fraud Risk/Fraud Prevention (Exhibit 1 - PowerPoint p. 10) See Exhibit 6: Common Fraud Patterns and Indicia in Publicized Cases 2
5 V. Investigating Fraud (p. 11) A. Techniques for Investigating Fraud B. When and How to Conduct Internal Investigations (p. 12) 1. Factors i. Why ii. When iii. Who conducts 2. Concerns/current issues 3. Enforcement priorities 4. Report i. Written, or ii. No written report iii. Remedial measures C. Ethical Considerations (Exhibit 1 -- PowerPoint p. 13) VI. Whistleblower provisions 1. Dodd Frank a. Exchange Act 21F b. Exchange Act Rule 21F-1 2. Best practices 3. Previously -- whistleblower recovery limited to insider trading cases VII. Concluding thoughts E:\MW\NSCP Presentations\Legal Outline Fraud and Misappropriation doc 3
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