On December 6, 2016, in an opinion written by Justice Alito, the Supreme Court unanimously affirmed the Ninth Circuit’s decision in Salman v. United States, a closely-watched insider trading tipping case. Salman builds upon...more
As noted in our November 21, 2016, Client Alert, Federal Energy Regulatory Commission (FERC or the “Commission”) Enforcement staff published two white papers—one on energy trading compliance, the other on market manipulation...more
On October 7, 2016, the Integrity Vice President (INT) of the World Bank Group (the “Bank”) released its annual report for fiscal year 2016 (the “Report”). In the Report, INT provides insight into the Bank’s efforts to combat...more
On October 2, 2016, the National Security Division (NSD) of the U.S. Department of Justice (DOJ) established a formal, voluntary self-disclosure program for criminal violations of U.S. economic sanctions and export controls...more
On November 16, 2015, the U.S. Department of Justice revised the United States Attorneys’ Manual (USAM) to align the principles by which federal government prosecutors investigate and prosecute criminal cases involving...more
On September 9, 2015, the U.S. Department of Justice issued guidance regarding the prosecution of individuals in cases involving criminal and civil corporate wrongdoing. The first major policy memorandum issued since Attorney...more
In recent years, taking advantage of expanded jurisdictional provisions in Dodd-Frank, the U.S. Securities and Exchange Commission (SEC) has brought an increasing number of enforcement actions, including complex matters with...more
On April 21, 2015, the U.S. Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) issued a Geographic Targeting Order (“GTO”) lowering reporting thresholds and triggering additional recordkeeping requirements...more
In a landmark insider trading decision issued on December 10, 2014, the U.S. Court of Appeals for the 2nd Circuit made important pronouncements favorable to the defense on two recurring and important legal issues: (1) what is...more
On November 10, 2014, the Supreme Court (No. 14-389) declined to review the 3rd Circuit decision (No. 13-1237), In Re: Grand Jury Subpoena, leaving intact the 3rd Circuit’s ruling on the proper bounds of the crime-fraud...more
On October 6, 2014, the Supreme Court declined to review the 11th Circuit’s decision in U.S. v. Esquenazi, et. al., leaving standing the appellate court’s expansive definition of “foreign official” under the Foreign Corrupt...more
In a speech delivered on June 5, 2014 at the Sandler O’Neill Global Exchange and Brokerage Conference in New York, U.S. Securities and Exchange Commission (SEC) Chair Mary Jo White unveiled a package of SEC initiatives aimed...more
On November 20, 2013, during a panel presentation at the 30th International Conference on the Foreign Corrupt Practices Act (“FCPA”), current and former prosecutors from the United States and the United Kingdom discussed the...more
On November 19 and 20, 2013, the American Conference Institute held the 30th annual U.S. Foreign Corrupt Practices Act (“FCPA”) conference outside of Washington, D.C. In addition to keynote addresses by U.S. Department of...more
Companies all over the globe are increasingly aware of the record number of corporate criminal enforcement actions brought in recent years by enforcement authorities to combat corruption, and many companies now are also...more
What's the one thing missing from most corporate compliance programs?
For a legal perspective, that's the question we put to corporate attorneys writing on JD Supra, asking each to commit to just one essential element...more
11/13/2013
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