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Treasury Department Releases AML Study on the Art Market

On Jan. 1, 2021, Congress passed the Anti-Money Laundering Act of 2020 (AMLA) which expanded the definition of “financial institution” to impose anti-money laundering (AML) requirements on persons “engaged in the trade of...more

DOJ Criminal Division Head Kenneth Polite Cautions Compliance Crackdown

Key Takeaways - Corporate enforcement and individual accountability are high priorities for new DOJ Criminal Division head Kenneth Polite. Companies should be proactive in implementing, monitoring, and improving their...more

NFT Scandals Coincide with Increased Push for Crypto Regulation

Problems caused by the lack of regulation in NFT markets were clearly exposed just last month with the revelation of not one, but two NFT scandals involving the use of insider information to snag exclusive pieces and game the...more

Digital Art: Collectible or Security?

Fractionalized non-fungible tokens (NFTs) have become increasingly popular within the ever-developing field of cryptocurrency, particularly in the distribution of digital art. NFTs use the same technology behind...more

Expanded Measures Impose AML Overhaul on Art and Antiquities Market

On July 28, 2020, the U.S. Senate Permanent Subcommittee on Investigations released its findings on the role of the unregulated art market in undermining U.S. sanctions policies and facilitating criminal activity....more

[Webinar] Paycheck Protection Program 2.0: What Borrowers Need to Know - February 22nd, 11:00 am - 12:30 pm EST

The Economic Aid to Hard-Hit Small Businesses, Nonprofits and Venues Act (Economic Aid Act), enacted into law on December 27, 2020, provides additional, much-needed relief to businesses and families economically impacted by...more

Important Lessons from the DOJ's First Civil Action for CARES Act Loan Fraud

On January 12, 2021, the Department of Justice (the “DOJ”) settled its first civil action for alleged fraud against the Paycheck Protection Program (the “PPP”) – the primary lending program under the Coronavirus Aid, Relief,...more

SEC Commissioner Peirce Delivers a Speech on Defining the Parameters of CCO Liability

The question of how to define the parameters of personal liability for compliance officers in the financial services industry has been around for several years. In a 2015 speech, then-SEC Enforcement Director Andrew Ceresney...more

The First of Many Expected COVID-19 Criminal Cases Against Nursing Home Operators

On September 24, 2020, Superintendent Bennett Walsh and former Medical Director David Clinton of the Soldiers’ Home in Holyoke, Massachusetts (SHH) were indicted on criminal neglect charges in what Attorney General Maura...more

DOJ Releases First FCPA Advisory Opinion in Six Years

On August 14, 2020, the Department of Justice (the “DOJ”) issued its first Foreign Corrupt Practices Act (the “FCPA”) advisory opinion in almost six years....more

DOJ and SEC Publish New FCPA Resource Guide

On the eve of the July 4th holiday, the Criminal Division of the Department of Justice (the “DOJ”) and the Enforcement Division of the Securities and Exchange Commission (the “SEC”) quietly published the second edition of the...more

DOJ Makes Important Changes to Its Guidance on Evaluating Compliance Programs

On June 1, 2020, the Criminal Division (the “Criminal Division”) of the Department of Justice (the “DOJ” or “Department”) issued revised guidance (the “June 2020 Guidance”) about how it will evaluate corporate compliance...more

First Paycheck Protection Program Fraud Charges Give Insight into Government Stimulus Investigations and Enforcement

On May 5, 2020, the Department of Justice (the “DOJ”) brought its first charges for defrauding the CARES Act Paycheck Protection Program (the “PPP”)....more

On the Heels of the CARES Act, Companies Should Prepare for Increased Prosecutions and Enforcement Activity

The Coronavirus Aid, Relief and Economic Security Act (the “CARES Act” or the “Act”) provides over $2 trillion in economic relief to eligible businesses and individuals affected by the COVID-19 pandemic. As with prior...more

SEC Chief Enforcement Accountant Cites the Use of Data Analytics, Self-Disclosure and Cooperation as Key Factors in Investigating...

With more than 130 highly trained enforcement accountants at his disposal, Matthew Jacques, the Chief Accountant of the Securities and Exchange Commission (“SEC”), provided a firsthand glimpse into current enforcement...more

[Webinar] Department of Justice - Antitrust and White-Collar Investigations - What You Should Know - October 23rd, 1:00 pm ET

BakerHostetler invites you to join us for an upcoming webinar, Department of Justice - Antitrust and White-Collar Investigations - What You Should Know, offering vital insights into antitrust issues and white-collar...more

Two Years Since Sapin II: Is France Now a Player in the Global Anti-Corruption Enforcement Arena?

In December 2016, the French Parliament passed a landmark anti-corruption law, Law No. 2016-1691 on Transparency, Fighting Corruption and Modernising Economic Life (the “Sapin II” or the “Law”), which strengthened the...more

Clarity and Transparency: DOJ Issues Updated Corporate Compliance Guide

On April 30, 2019, the Criminal Division of the U.S. Department of Justice ("DOJ") released a new corporate compliance guidance document for prosecutors titled “Evaluation of Corporate Compliance Programs” (“Guidance”)....more

The House Always Wins: The DOJ Reverses Itself On The Wire Act

On January 14, 2018, the U.S. Department of Justice expanded restrictions on online gambling, publicly releasing a November 2, 2018 opinion (the “Opinion”) from its Office of Legal Counsel. The opinion reversed DOJ’s previous...more

DOJ's New Guidance on Monitorships: Reaffirming the Importance of Compliance and Preventing Misconduct

On October 12, 2018, at the NYU School of Law Program on Corporate Compliance and Enforcement Conference, Brian A. Benczkowski, Assistant Attorney General for the Department of Justice’s Criminal Division, announced new...more

Foreign Corrupt Practices Act 2017 Year-End Update

2017 marked the fortieth anniversary of the Foreign Corrupt Practices Act (FCPA), and showed continued robust enforcement against both individuals and companies by the U.S. Department of Justice (DOJ) and the U.S. Securities...more

2017 Year-End Securities Litigation and Enforcement Highlights

Welcome to the 2017 Year-End Report from the BakerHostetler Securities Litigation and Regulatory Enforcement Practice Team. The purpose of this report is to provide a periodic survey of matters we believe to be of interest...more

ISO 37001: Testing the Ability to Implement a Global Anti-Bribery Standard

A year after a global anti-bribery standard was implemented by the International Standards Organization (“ISO”), a slow trend is emerging among major corporations, such as Microsoft and Wal-Mart, announcing they will seek...more

Multinationals Need to Pay Attention to China's Anti-Corruption Campaign

The People’s Republic of China continues to modify its anti-corruption enforcement regime through its new pilot program and the adoption of recent amendments to its anti-corruption laws. In China, there are two major...more

New French Anti-Corruption Law: Companies Doing Business in France Must Beware

On November 8, 2016, France modernized its anti-corruption enforcement regime and adopted the Law on Transparency, the Fight against Corruption and Modernization of Economic Life (known in France as “Sapin II,” named after...more

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