Podcast - Discussing a DOJ Lawsuit Under the Civil-Fraud Initiative
Navigating Regulatory Waters: Recent Enforcement Actions in BaaS — Payments Pros – The Payments Law Podcast
The Presumption of Innocence Podcast: Episode 47 - Fireside Chat With Bill Baroni and Jesse Eisinger
Episode 340: DOJ Updates Evaluation of Corporate Compliance Programs
Public-Private Partnerships to Stem Corruption
Episode 339: Four Sanctions Cases Everyone Should Know
Enhancing Compliance: The Power of Independent Monitorships in Consumer Protection — Regulatory Oversight Podcast
Episode 338 -- Deep Dive into the Deere SEC FCPA Case
The Legal Tightrope: Surviving Parallel Investigations
Navigating Government Contracts: Diana Shaw on Oversight and Whistleblower Protections
The Presumption of Innocence Podcast: Episode 45 - The Grit, Grace and Gift of Second Chances
The Justice Insiders Podcast - The Ever-Expanding Net: Corporate Compliance in an Era of Increasing Trade Sanctions and Restrictions
False Claims Act Insights - Are All Healthcare “Kickbacks” Subject to FCA Liability?
Episode 333 -- The Boeing Proposed Plea Agreement
DOJ’s New Self-Disclosure Policy and Corporate Whistleblower Awards Pilot Program
False Claims Act Insights - Assessing the Fallout from a Thermonuclear FCA Verdict
FCPA Survival Guide - Step 8 - Investing in Compliance
Exploring the AI and Crypto Intersection
The Justice Insiders Podcast: Jarkesy’s Implications for the Administrative State
The Presumption of Innocence Podcast: Episode 41 - The Dynamics of Decision-Making: Psychology and the Criminal Justice System
In December 2023, we published an alert concerning US Securities and Exchange Commission ("SEC") Chair Gary Gensler's warning to public companies against "AI washing" – that is, making unfounded claims regarding artificial...more
On July 21, 2023, a three-judge panel of the Fifth Circuit Court of Appeals issued an opinion asserting that the Commodity Futures Trading Commission’s Division of Market Oversight likely acted arbitrarily and capriciously,...more
A bipartisan bill introduced in the U.S. Senate last week seeks “to bring crypto assets within the regulatory perimeter” by granting oversight responsibility to the Commodity Futures Trading Commission (CFTC) for most forms...more
Highlights of the Last Two Weeks in Blockchain+ The Blockchain Bi-Weekly presented by the Polsinelli Blockchain+ team is a rundown of some of the key stories in the Web3, blockchain and crypto ecosystems curated by our...more
This is the eighth part in our 2023 series examining important trends in white collar law and investigations. Up next: anti-corruption. The tumultuous crypto events of 2022, combined with the heightened agency and executive...more
Federal enforcement agencies continue to scrutinize investment advisers’ use of personal devices and messaging platforms to conduct business. Our team reviews how recent penalties should encourage companies to create internal...more
In last week's Cabinet News and Views, we examined the U.S. regulators' approach to the digital asset space, with a focus on the assertion of jurisdiction by the CFTC, the SEC, prudential regulators, state executive and...more
In the wake of President Biden’s March 9, 2022, executive order outlining his Administration’s desire to establish a comprehensive federal approach to crypto policy and regulation, federal agencies are continuing to focus on...more
Described as the "Wild West" by SEC Chairman Gary Gensler, the meteoric rise of digital assets like cryptocurrencies has disrupted the traditional financial ecosystem. The wave of enforcement actions brought by federal and...more
U.S. Developments - 1. Unamended Infrastructure Bill with “Broker” Reporting Requirements Set for Vote in September - The U.S. House of Representatives locked in a date of September 27, 2021, for the vote on a $1...more
On August 10, 2021, the Commodity Futures Trading Commission (CFTC) announced that the US District Court for the Southern District of New York entered a consent order against HDR Global Trading Limited, 100x Holding Limited,...more
Recent and significant regulatory and legislative events in the digital asset space demonstrate the evolving and expanding approach by U.S. and international regulators to the burgeoning digital asset markets. These...more
On August 31, 2020, the Office of Information and Regulatory Affairs (OIRA), within the Office of Management and Budget (OMB), issued a memorandum to all executive departments and agencies on reforming regulatory enforcement...more
In 2019, the Commodity Futures Trading Commission (CFTC or Commission) experienced significant changes in leadership, including the appointment of Dr. Heath P. Tarbert as the Commission’s 14th Chairman. The Division of...more
This BitBlog summary focuses on the continuing actions by the U.S. Securities and Exchange Commission (“SEC”) against the issuers of noncompliant initial coin offerings (“ICOs”) and other crypto related transactions including...more
Two important events occurred in the cryptocurrency space last week. The Chairman of the US Commodity Futures Trading Commission (CFTC) gave a speech regarding regulators’ role in effectively supervising markets in the era...more
Upcoming Bitcoin exchange-traded funds (“ETF”) Decisions - On January 4, 2018, NYSE Arca filed a proposed rule change to list 9 Bitcoin ETFs. Subsequently, the time for the Security Exchange Commission (“SEC”) to approve or...more
On August 28, 2018, the Division of Swap Dealer and Intermediary Oversight (DSIO) of the Commodity Futures Trading Commission (CFTC) released a staff no-action letter allowing an anonymous individual financial institution...more
With soaring cryptocurrency prices attracting significant new investment in late 2017, U.S. regulators sought to fill the statutory void by exercising jurisdiction over a variety of digital assets. That trend continued in the...more
Last week, former CFTC Chairman Gary Gensler explained in remarks at M.I.T. that he believes the second and third most widely used virtual currencies—Ether and Ripple—may have been issued and traded in violation of securities...more
After months of steadily increasing supervisory activity in regard to the emerging cryptocurrency sector, it now appears that U.S. financial market regulators may have switched gears and entered the enforcement stage....more
Below is a summary of some of the significant legal and regulatory actions that occurred over the past week. This alert is not intended to be a comprehensive list of all such developments, but rather a selection of...more
Virtual currencies have risen from a little known tech curiosity to what some see as the next great investment opportunity in contrast to others who see little but fraud. An alphabet soup of regulators are struggling to apply...more
As we previously have blogged, the Financial Crimes Enforcement Network (“FinCEN”) became one of the first regulators to wade into the regulation of cryptocurrency when it released interpretive guidance in March 2013 stating...more
The Commodity Futures Trading Commission (CFTC or Commission) Chairman J. Christopher Giancarlo issued a statement this week on virtual currencies. The CFTC also released a backgrounder on its oversight of and approach to...more