Since April the Department of Justice has been running a Kool-Aid stand and many people have been drinking the Kool-Aid. The Kool-Aid being served up and consumed is Morgan Stanley’s so-called declination….
Morgan Stanley may indeed have being doing the right thing in its compliance program and for that it deserves credit. However… The reason Morgan Stanley was not prosecuted for Peterson’s actions is because there was no basis to hold Morgan Stanley liable even under lenient respondeat superior standards.
via Stop Drinking The Kool-Aid — FCPA Professor
