In April 2024, the SEC filed 21 actions and the CFTC filed 1, against a combined total of 31 defendants and respondents. (These figures exclude follow-on actions, bars and suspensions.) T...
The DOJ Criminal Division announced a new individual self-disclosure pilot program designed to “up the ante” on companies calculating the risk of not disclosing misconduct. The progr...
The DOJ’s National Security Division recently updated its voluntary self-disclosure policy, highlighting the importance of sanctions and export control-related due diligence in M&A tran...
A new proposal would require U.S. companies to comply with U.S. government cybersecurity standards before transferring bulk data to, or accepting investment from, companies based in targe...
DOJ recently announced that it will launch a pilot program to pay individual whistleblowers who report wrongdoing to the DOJ. The initiative supplements existing SEC, CFTC and other such ...
The U.S. Attorney’s Office for the Southern District of New York (SDNY) announced the creation of a Whistleblower Pilot Program applying to individuals who provide information regarding...
SAP agreed to pay $220 million to resolve a long-standing foreign bribery investigation with the Department of Justice and the Securities and Exchange Commission involving improper paymen...
The recently enacted Foreign Extortion Prevention Act, meant to serve as the mirror image of the Foreign Corrupt Practices Act, criminalizes the solicitation and receipt of bribes by fore...
In a recent speech, Acting Assistant Attorney General Nicole M. Argentieri laid out how the DOJ is increasing its use of data analytics to proactively identify FCPA cases, deepening its c...
On October 17, 2023, CFTC Director of Enforcement Ian McGinley signaled a more aggressive approach by the agency in new enforcement guidance addressing penalties, admissions, the impositi...
