Jennifer Moore is a veteran of the SEC's FCPA unit, currently working as a senior counsel. She is based in the commission’s Salt Lake City, Utah office, where she has worked for the SEC since 1999.
Moore led a foreign bribery investigation into Nordion, a Canadian health sciences company, which in March 2016 entered into an administrative settlement with the SEC over a scheme to bribe Russian officials for a permit to distribute a liver cancer treatment. The former Nordion employee responsible for the scheme, Mikhail Gourevitch, also settled with the SEC, paying a US$66,000 civil penalty, US$100,000 in disgorgement and US$12,950 in prejudgment interest. Nordion, meanwhile, agreed to a US$375,000 civil penalty for lacking internal accounting controls and for failing to perform basic FCPA due diligence to prevent Gourevitch’s alleged misconduct.
Moore was involved in an FCPA-turned-embezzlement case against the former chief financial officer of Digi International, a computer networking company, who was charged with books and records violations for improperly recording unauthorised travel and entertainment expenses. Subramanian Krishnan, the CFO, agreed to settle the SEC’s charges in 2012.
Outside the FCPA realm, Moore conducted a fraud investigation into a Utah resident who allegedly solicited investments in “top secret” Iraqi currency and oil contracts. The US Attorney’s Office for the District of Utah also brought parallel criminal charges against the resident, John Scott Clark, who pleaded guilty to securities fraud. Clark paid US$1.7 million in criminal restitution and was sentenced to serve 36 months in prison.
Moore was also involved in an SEC enforcement action against five World Group Securities executives, who were charged by the agency in 2008 with selling unsuitable securities.