Ms. Vasady-Kovacs counsels a wide range of clients on campaign finance; pay-to-play reporting; lobbying; MSRB G-37 filings; political contributions, gift and entertainment expenditures; Foreign Corrupt Practices Act (FCPA) best practices; as well as corporate compliance with federal securities laws. She regularly advises clients on federal securities laws, trading rules and regulations, and NYSE administrative, investigative, and enforcement procedures and litigation. She also counsels clients on regulatory issues including policies and procedures, internal controls and global anti-corruption programs, including FCPA. Ms. Vasady-Kovacs' prior service in both the public and private sectors well equips her to translate legal and regulatory issues strategically in relation to investigations, litigations, and the development of robust compliance programs to allow businesses to expand globally while minimizing their legal and compliance risks.
Prior to joining Kelley Drye, Ms. Vasady-Kovacs held several in-house positions at well-known financial institutions. From 2006 to 2009, she served as a Director for the Americas Compliance Department for Deutsche Bank where she managed the political law and internal control activities for their U.S. entities. During her tenure at Deutsche Bank, she co-managed the FCPA Compliance process and assisted in drafting several global anti-corruption policies. From 2005 to 2006, Ms. Vasady-Kovacs served as a Vice President and Counsel in Compliance for Morgan Stanley, working to build the institution's compliance with NASD and NYSE rules 3012, 3013, 342, as well as advising on new and proposed securities laws and rules.
From 1998 to 2005, Ms. Vasady-Kovacs held the position of Trial Counsel for the New York Stock Exchange where she investigated and prosecuted brokers and member organizations for violations of Exchange Rules and federal securities laws. She handled cases by the Divisions of Market Surveillance and Member Firm Regulation, negotiated settlements, conducted contested administrative hearings before the NYSE Hearing Panel, participated in investigative task forces, and handled appeals.
From 1996 to 1998, Ms. Vasady-Kovacs served as Assistant Counsel in the Office of the State Inspector General where she conducted investigations and drafted reports on fraud, corruption, crime and abuse in state government. Prior to her tenure in the Inspector General's Office, she served as Assistant District Attorney in the New York County District Attorney's Office.
Representative Experience
Political Contributions- Responsible for vetting all corporate U.S. employee political contributions, entity-wide.
- Performed pay-to-play reporting on behalf of corporate entities.
- Developed a corporate Compliance Political Activities intranet site and dedicated email and telephone line to assist employees.
- Worked with SIFMA and the Political Law group (industry group) to coordinate efforts to reduce the breadth and impact of proposed state and local legislation.
- Led corporate efforts to assess New Jersey pay-to-play contract certification requirements and propose an option to mitigate risk to allow the firm to begin to do derivatives business in New Jersey.
- Initiated plans to efficiently obtain information from corporate senior management within the confines of firm policy and European and U.S. laws, to assist corporate entities in becoming eligible for future business in pay-to-play jurisdictions with new reporting requirements.
Developed and managed the quarterly MSRB G-37 filing and record keeping requirements, a process initiated in 2007 in order to enable corporate expansion of business into municipal underwritings and bond offerings. This included the following:
- Coordinated with Compliance Advisors and Legal to clear all potential municipal securities transactions.
- Prepared and submitted quarterly G-37 filings to the MSRB.
- Internally maintained the required G-8 report which lists all current employees designated Municipal Finance Professional (“MFPs”) and Non-MFP Executive Officers and tracks their activities and supervisory relationships over time.
- Addressed the restrictions and reporting requirements placed on MFPs and Non-MFP Executive Officers when Governor of Alaska, Sarah Palin was nominated as the Republican candidate for Vice President.
- Provided immediate certification information and research to allow corporate entities to bid on government contracts.
- Coordinated and conducted a targeted review of employees covering across approximately 42 state and local jurisdictions.
- Identified and assessed 132 business relationships requiring legal assessment across multiple business lines and involving approximately 55 employees and 42 jurisdictions.
- Responsible for reviewing all requests to host events or provide gifts and/or entertainment to Public Officials, both internationally and in the U.S.
- Developed Supervisory Control and CEO Certification processes in response to NASD Rules 3012 and 3013 (now FINRA Rule 3130) and assisted in developing a reporting and tracking process for firm senior management.
- Responsible for the Annual Compliance Reports, pursuant to NYSE Rule 342.
