What Compliance Officials Must Know About Market Screening

Law360, New York (September 29, 2015, 4:41 PM EDT) -- Competition authorities and regulatory bodies are resolute in encouraging companies to beef up their corporate compliance programs. In the Libor investigation, for example, the U.S. Department of Justice required Barclays PLC and other banks to “maintain or develop monitoring systems or electronic exception reporting systems that identify possible improper or unsubstantiated submissions.” [1] Similar agreements were reached between various banks and the U.S. Commodity Futures Trading Commission. In the recent forex investigation, the DOJ took notice of Barclays' efforts and stated in its plea agreement: “The parties further agree that the Recommended Sentence is sufficient ... in considering, among other factors,...

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