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DOJ Releases Guidance on Corporate Practices Concerning Employees’ Use of Personal Devices, Communications Platforms, and...

Summary - The U.S. Department of Justice issued a revised policy for Evaluation of Corporate Compliance Programs (ECCP), with new guidance on how the DOJ will consider corporate procedures for employees’ business-related...more

DOJ's Revisions to the Corporate Enforcement Policy Incentivize Self-Reporting of Misconduct

Summary - The Department of Justice (DOJ) last week issued revisions to the Criminal Division’s Corporate Enforcement Policy that incentivize companies to promptly self-disclose corporate misconduct, cooperate with the DOJ,...more

New DOJ Memo Includes Significant Changes to Corporate Crime Policies

Summary - A new memorandum from Deputy Attorney General Lisa Monaco, released on September 15 (Memorandum), represents one of the most comprehensive updates in years to the approach of the U.S. Department of Justice (DOJ) in...more

DOJ Again Charges Crypto “Mixer” Under the BSA and District of Columbia’s Money Transmitters Act

In Related Case, Federal Court Holds that Bitcoin-to-Bitcoin “Tumbler” Can Represent “Money Transmission” On April 27, IRS CI and FBI Special Agents arrested Roman Sterlingov, a dual citizen of Russia and Sweden, for his...more

DOJ Unseals Indictment Charging Three North Korean Military Intelligence Operatives With Attempting to Steal Over $1 Billion in...

Related Money Laundering Case Relying on ATM Cash-Outs and BEC Schemes Also Unsealed - On February 17, the Department of Justice unsealed a sprawling indictment against three members of North Korea’s military intelligence...more

D.C. Circuit Rules in Favor of Broad Reach of Patriot Act Subpoenas

On August 6, the U.S. Court of Appeals for the District of Columbia kept in place $50,000-per-day fines on three Chinese banks—whose identities are redacted—for refusing to comply with subpoenas issued by the Department of...more

Use of Tainted Assets to Pay Attorney Fees: A Primer on the Pitfalls

On August 29, the Wall Street Journal reported (paywall) a story that other news outlets later have picked up: the Department of Justice (“DOJ”) is investigating whether Jho Low, a Malaysian businessman at the center of the...more

2016 Year End Review: Virtual Currency: DOJ and IRS Broadly Seek Virtual Currency Account User Information

Under Internal Revenue Code section 7609(f), the IRS may issue a “John Doe” administrative summons to discover the identities of unknown taxpayers. A “John Doe” summons can be a powerful enforcement tool because it allows the...more

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