Throughout the week over at Securities Docket I highlight the most interesting columns and blog posts from around the web on the subjects of SEC enforcement and securities litigation. Here is a digest of my picks for the week ending December 2.

For Wall Street Watchdog, All Grunt Work, Little Glory
DealBook | Ben Protess | Dec 1, 2011
In an office park 20 miles outside Washington, the Financial Industry Regulatory Authority, Wall Street's nonprofit self-regulator, has quietly built a small army of market police. Since Wall Street's financial crisis in 2008, this fledgling fraud task force has entered the front lines of fighting insider trading, even if the group rarely earns the credit.

The SEC and the Courts: Challenging the Citigroup Decision
TheRacetotheBottom.org | J. Robert Brown Jr. | Dec 1, 2011
The reasoning of this decision cannot be left unchallenged.... So what might the SEC do?  It could seek voluntary dismissal and refile (and settle) the case as an administrative proceeding.  That, however, would leave the legal analysis in Citigroup unchallenged. The Commission could seek reconsideration of the decision and, in the alternative, an interlocutory appeal.  The trial court will not reverse his decision but with a spirited challenge he may at least narrow the holding. The same is true with respect to an appeal....

Surely The SEC Is Sick Of Going To Court By Now?
Dealbreaker | Matt Levine | Nov 29, 2011
So the SEC can get (1) money and (2) reasonable assurance that Citi will try really hard not to do more terrible things without any court approval. In fact, the SEC did exactly that with Credit Suisse in this case.... So why didn't they do that with Citi? Why didn't the SEC and Citi just agree on what the deal was and announce it in a press release, rather than agree on what the deal was and announce it in a press release and submit it to a judge who just hates, hates, hates the SEC and who they had to know would call them out for being generally all-around shoddy re: this whole Citi thing?

Scare the Crap Out of Them
Open Air | Howard M. Sklar | Nov 29, 2011
Our dirty little secret, if this could rightly be called that, is that we practitioners vastly overstate the risk that the FCPA brings to companies. In-house Compliance officers have a good reason for it: we need to spur change. In order to get a corporation, especially a large multi-national corporation, to move you sometimes need a significant amount of pressure to overcome its inertia. Once you get things moving—that is, get budget, resources, and priorities—around the effort, momentum and positive inertia will keep you going.

Is the Judiciary about to Give the SEC a Backbone?
The Accounting Onion | Tom Selling, PhD | Nov 29, 2011
As one can plainly see, Judge Rakoff has frequently rejected the SEC's interpretation of the law and the facts. It deeply saddens me to see how the agency that I worked with and long admired has become a shell of its former self – brought on by a lack of resources, a lack of will among its leadership to pursue cases, and the ever spinning revolving door. But, the SEC needs more than a single ruling in a federal district court to get it back on track. The SEC sorely needs new leadership: someone with a sense of history, vision and a backbone. Actually, it needs someone like Judge Rakoff. But, at least for today, I'll have the satisfaction of knowing that someone is finally insisting on making securities law violators, no matter how well politically connected, fully accountable for their actions.

The UK Bribery Act: Engagement With Companies And Compliance Effects
FCPA Professor | Richard Alderman | Nov 29, 2011
In the months since the UK Bribery Act came into force on July 1st 2011, there is one question that I have probably been asked more than any other: what are we actually doing under the Act at the SFO? ... In my view, many people would regard the SFO as taking a rather lazy and unreflective approach if we pursued easy ‘quick wins' rather than the really difficult and more serious cases.... The plain answer is that we're actively looking for cases to take up – but these cases are the difficult ones. For example, we have been examining the activities of a number of foreign companies with a UK business presence who are involved in bribery in other countries.

It's cognitive dissonance time at the SEC
News & Insight | Robert Fusfeld | Nov 29, 2011
The Securities and Exchange Commission needs to completely reform how it measures the effectiveness of its enforcement efforts. The SEC's reliance on penalties has lost its deterrent effect and many firms seem to treat those huge penalties as simply a cost of doing business.