The Development: On August 1, 2024, the Department of Justice's ("DOJ") Criminal Division announced its Corporate Whistleblower Awards Pilot Program ("Pilot Program"), designed to reward whistleblowers who report information...more
8/20/2024
/ CFTC ,
Corporate Misconduct ,
Department of Justice (DOJ) ,
False Claims Act (FCA) ,
Financial Crimes ,
Financial Institutions ,
FinCEN ,
Foreign Corrupt Practices Act (FCPA) ,
Healthcare Fraud ,
Money Laundering ,
Pilot Programs ,
Securities and Exchange Commission (SEC) ,
Whistleblower Awards ,
Whistleblowers ,
White Collar Crimes
The recently created SDNY Whistleblower Pilot Program encourages individuals to self-disclose certain criminal conduct and cooperate in resulting investigations and prosecutions.
...more
2/8/2024
/ Anti-Corruption ,
Corruption ,
Criminal Investigations ,
Criminal Liability ,
Department of Justice (DOJ) ,
New York ,
Non-Prosecution Agreements ,
Pilot Programs ,
Self-Disclosure Requirements ,
Whistleblower Protection Policies ,
Whistleblowers ,
White Collar Crimes
Foreign Corrupt Practices Act (“FCPA”) enforcement continues to slowly rebound from pre-pandemic levels. In 2023, the Department of Justice (“DOJ”) and the Securities and Exchange Commission (“SEC”) resolved 13 corporate FCPA...more
In light of the DOJ’s most recent guidance on the use of personal devices and third-party messaging applications by corporate personnel, this White Paper addresses issues and challenges that companies are facing in this area...more
10/18/2023
/ CFTC ,
Compliance ,
Cybersecurity ,
Data Collection ,
Data Privacy ,
Data Protection ,
Department of Justice (DOJ) ,
Electronic Communications ,
Financial Industry Regulatory Authority (FINRA) ,
Guidance Update ,
Instant Messaging Apps ,
Mobile Devices ,
Policies and Procedures ,
Securities and Exchange Commission (SEC) ,
White Collar Crimes ,
Workplace Communication
Under a new U.S. Department of Justice ("DOJ") policy related to mergers and acquisitions ("M&A"), DOJ will decline to prosecute an acquiring company for misconduct by an acquired company where the acquiring company timely...more
In Short -
The Situation: As a follow-up to the deputy attorney general's September 2022 memorandum, the U.S. Department of Justice ("DOJ" or "Department") announced in March 2023 significant updates to its corporate...more
On February 22, 2023, the U.S. Department of Justice ("DOJ" or "Department") announced the Voluntary Self-Disclosure Policy ("VSD Policy" or "Policy"), detailing the circumstances under which a company can receive credit for...more
Foreign Corrupt Practices Act (“FCPA”) enforcement has yet to rebound from the immediate pre-pandemic period. In 2022, DOJ and SEC resolved eight corporate FCPA matters for $878 million, including four resolutions coordinated...more
3/3/2023
/ Anti-Bribery ,
Anti-Corruption ,
Anti-Money Laundering ,
Bribery ,
Compliance ,
Corporate Counsel ,
Corporate Crimes ,
Corruption ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Foreign Corrupt Practices Act (FCPA) ,
Money Laundering ,
Securities and Exchange Commission (SEC)
In Short -
The Situation: Decentralized finance ("DeFi") is a rapidly growing sector that, by definition, eschews centralized financial institutions altogether. Misconduct that has accompanied that growth has drawn the...more
In Short -
The Situation: On January 17, 2023, the U.S. Department of Justice ("DOJ" or "Department") announced significant revisions to the Criminal Division's Corporate Enforcement Policy....more
In Short -
The Situation: On September 15, 2022, Deputy Attorney General Lisa Monaco announced significant changes and updates to the Department of Justice's corporate criminal enforcement policies. ...more
The Biden administration took office in January 2021, announcing aggressive and sweeping anticorruption initiatives to tackle corruption around the world, labeling corruption a national security priority, and signaling a...more
1/28/2022
/ Anti-Corruption ,
Biden Administration ,
Compliance ,
Corruption ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Foreign Corrupt Practices Act (FCPA) ,
National Security ,
Securities and Exchange Commission (SEC) ,
Whistleblowers ,
White Collar Crimes
Introduction In the first 10 months of the Biden administration, senior DOJ officials have signaled a renewed focus on corporate criminal and civil enforcement against companies and individuals. ...more
The Department of Justice ("DOJ") and the Commodity Futures Trading Commission ("CFTC") in recent years have worked closely together to target companies and individuals for violations of the Commodity Exchange Act and other...more
In an effort to pursue unlawful trading in the derivatives markets, the U.S. Commodity Futures Trading Commission ("CFTC") and U.S. Department of Justice ("DOJ") have in recent years engaged in unprecedented levels of...more
4/29/2021
/ Analytics ,
CFTC ,
Civil Liability ,
Commodities ,
Commodities Traders ,
Commodity Exchange Act (CEA) ,
Cooperation ,
Criminal Liability ,
Department of Justice (DOJ) ,
Derivatives ,
Enforcement Actions ,
Fraud ,
Investigations ,
Market Manipulation ,
Parallel Proceedings ,
Spoofing