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Press Release

SCCE Chief Executive Officer Praises U.S. Department of Justice Decision to Recognize Compliance Efforts by Morgan Stanley

PR Newswire

MINNEAPOLIS, May 11, 2012 /PRNewswire-USNewswire/ -- The Society of Corporate Compliance and Ethics (SCCE) today applauded the government's decision to recognize Morgan Stanley's compliance efforts and not bring any enforcement action against the global financial services firm related to its former managing director for its real estate business in China, Garth Peterson. Peterson pleaded guilty April 25, 2012 to one-count criminal information charging him with conspiring to evade internal accounting controls that Morgan Stanley was required to maintain under the Foreign Corrupt Practices Act (FCPA).   

SCCE Chief Executive Officer Roy Snell remarked that "the first message being conveyed in the Morgan Stanley case is that those who make an effort to implement a compliance program will be rewarded.  The second message is that those who don't try to prevent, find and fix regulatory and ethical issues should take note."  

According to the Department of Justice's press release, "After considering all the available facts and circumstances, including that Morgan Stanley constructed and maintained a system of internal controls, which provided reasonable assurances that its employees were not bribing government officials, the Department of Justice declined to bring any enforcement action against Morgan Stanley related to Peterson's conduct.  The company voluntarily disclosed this matter and has cooperated throughout the department's investigation."

Noting Morgan Stanley's compliance efforts, the Department of Justice press release dated April 25, 2012 acknowledged that "According to court documents, Morgan Stanley maintained a system of internal controls meant to ensure accountability for its assets and to prevent employees from offering, promising or paying anything of value to foreign government officials.  Morgan Stanley's internal policies, which were updated regularly to reflect regulatory developments and specific risks, prohibited bribery and addressed corruption risks associated with the giving of gifts, business entertainment, travel, lodging, meals, charitable contributions and employment.  Morgan Stanley frequently trained its employees on its internal policies, the FCPA and other anti-corruption laws.  Between 2002 and 2008, Morgan Stanley trained various groups of Asia-based personnel on anti-corruption policies 54 times.  During the same period, Morgan Stanley trained Peterson on the FCPA seven times and reminded him to comply with the FCPA at least 35 times.  Morgan Stanley's compliance personnel regularly monitored transactions, randomly audited particular employees, transactions and business units, and tested to identify illicit payments.  Moreover, Morgan Stanley conducted extensive due diligence on all new business partners and imposed stringent controls on payments made to business partners." Click here for the DOJ press release:

About the SCCE
The Society of Corporate Compliance & Ethics (SCCE), headquartered in Minneapolis, MN, is a non-profit professional membership organization made up of compliance and ethics professionals. SCCE exists to champion ethical practice and compliance standards in all organizations and to provide the necessary resources for compliance professionals and others who share these principles. Visit the SCCE website at, Tel: 888-277-4977. Society of Corporate Compliance & Ethics is located at 6500 Barrie Road, Suite 250, Minneapolis, Minnesota 55435. Email:

SOURCE Society of Corporate Compliance and Ethics

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