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Reshaped Priorities: Navigating Changes to FCPA and FARA Enforcement

On February 10, 2025, President Donald Trump signed an Executive Order directing the Department of Justice (DOJ) to pause enforcement of the U.S. Foreign Corrupt Practices Act (FCPA), citing concerns over the competitive...more

Trump 2.0: A New Era for the Regulation of Cryptocurrency and Digital Assets

President Trump campaigned on the promise to make the United States the “crypto capital” of the world. In his first days in office, he took steps to advance that goal, including by signing an executive order designed to...more

Department of Justice Settles with Las Vegas Casino for $130 Million

The settlement is the latest example of the agency’s enhanced criminal enforcement of money transmitting business and international money-laundering laws. The recent settlement is significant both in terms of its amount...more

Don’t Forget to File (Accurately): 2024 Brings Heightened IRS and DOJ Focus on Non-Filers and Digital Assets

The IRS has increased funding for collection and enforcement, with a stated focus on high income non-filers and digital assets (among other areas). The DOJ has also emphasized a focus on digital assets, and the Department...more

Voluntary Self-Disclosure: Is the Value Self-Evident?

How should companies think about DOJ, BIS and OFAC voluntary disclosure in the wake of the DOJ’s massive investment in sanctions and export control enforcement? The DOJ, BIS and OFAC released a joint compliance note...more

Coinbase Contests the SEC’s Regulatory Authority over Crypto Exchanges, Staking

Arguments presented by Coinbase in its answer to SEC charges would, if accepted, potentially deprive the SEC of its most effective tool in regulating digital assets. The SEC alleges in a Complaint in SDNY that Coinbase...more

SCOTUS Upholds Civil RICO Lawsuit for a Foreign Defendant’s Acts in the United States to Evade Enforcement of a Foreign Arbitral...

The Supreme Court held that a defendant’s acts to prevent a foreign plaintiff from collecting on an overseas arbitration award in the U.S. may give rise to a civil RICO claim. The Court held that whether there is a U.S....more

China Amends the Counter-Espionage Law

With the amended Counter-Espionage Law, China has broadened its definition of “espionage” to give information related to “national security and interests” the same protections already given to state secrets. The amended...more

How Are Digital Assets Regulated in the United States and Elsewhere?

Continuing instability in the crypto sector highlights the need for clear regulation for efficient development, but how best to regulate is an ongoing debate. Recent instability in the crypto sector will only intensify the...more

SEC’s Heightened Scrutiny of Rule 10b5-1 Plans and Final Rulemaking Focus Is on Insiders Rather than Issuers

The SEC seeks to regulate trading through internal compliance processes. The SEC settled insider trading charges in relation to misuse of a Rule 10b5-1 plan established in the name of a British Virgin Islands entity owned...more

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