The SEC continues to pursue enforcement actions for major, as well as minor, infractions.  See our two-part series on the SEC’s “Broken Windows” Approach: Part One, Vol. 8, No. 37 (Sep. 24, 2015); and Part Two, Vol. 8, No. 38 (Oct. 1, 2015).  In this environment, hedge fund managers need to ensure they have sufficient compliance programs in place to guard against violations and ward off potential SEC actions.  Additionally, the financial services industry remains a prominent focus for Foreign Corrupt Practices Act (FCPA) enforcement, and the FCPA is becoming a more significant part of hedge fund compliance programs, particularly for those that invest or market globally.  For more, see “FCPA Compliance Strategies for Hedge Fund and Private Equity Fund Managers,” Hedge Fund Law Report, Vol. 7, No. 23 (Jun. 13, 2014).  Speakers at Corporate Counsel’s Ninth Annual Hedge Fund General Counsel and Compliance Officer Summit addressed the foregoing, illustrating elements of a robust compliance program and addressing FCPA requirements.  This article summarizes those panel discussions.  For additional coverage of the Summit, see “ALM General Counsel Summit Reveals How Hedge Fund Managers Can Prepare for SEC Examinations,” Hedge Fund Law Report, Vol. 8, No. 45 (Nov. 19, 2015).