On February 26, a long-running legal battle over the scope of the Foreign Corrupt Practices Act (“FCPA”) took another turn when a federal trial court judge ordered that former Alstom ...
On February 7, 2020, the Office of the Attorney General of California (CAL AG) released a modified version of its proposed regulations, which it further modified on February 10, 2020, und...
The SEC Office of Compliance Inspections and Examinations (OCIE) recently published observations related to cybersecurity and operational resiliency practices observed in its examinations...
Last week, the House overwhelmingly passed legislation aimed at closing what lawmakers have called a “loophole” for insider trading—corporate insiders trading between the occurrence...
To assist legal and compliance officers of financial institutions, this memorandum summarizes key recent developments in criminal prosecutions and regulatory enforcement actions involving...
FinCEN Director Kenneth A. Blanco recently stressed the value of BSA data, especially in the virtual currency space, and highlighted the continuing “national security gap” in collecti...
Assistant Attorney General Brian Benczkowski, the head of DOJ’s Criminal Division, recently gave a speech in which he clarified that DOJ will not automatically seek to impose agency lia...
The Department of Justice (“DOJ”) modified its Corporate Enforcement Policy to clarify what level of disclosure is expected from companies in the early stages of an investigation. In...
The SEC’s Enforcement Division (the “Division”) released its annual report on November 6. The Division filed 7% more standalone cases in 2019 than it did in 2018, and financial sanc...
On Friday, November 1, 2019, the Supreme Court granted certiorari in Liu v. Securities and Exchange Commission, a case that challenges the SEC’s long-held position that it has authorit...
