In a high-profile dispute between federal prosecutors and the Los Angeles Angels relating to criminal charges filed in the aftermath of a tragic overdose and death of an Angels pitcher, the government went on the offensive...more
1/13/2022
/ Attorney-Client Privilege ,
Controlled Substances ,
Corporate Counsel ,
Crisis Management ,
DEA ,
Federal Rules of Civil Procedure ,
Internal Investigations ,
Motion to Compel ,
Privilege Waivers ,
Privileged Communication ,
Public Relations ,
Public Statements ,
Subpoenas ,
Third-Party
On December 21, 2021, the U.S. Department of Justice (“DOJ”) announced a resolution of its criminal investigations into NatWest Markets Plc (“NatWest”), a global banking and financial services firm based in the United...more
1/12/2022
/ Banking Sector ,
Corporate Counsel ,
Corporate Monitoring ,
Department of Justice (DOJ) ,
Financial Services Industry ,
Foreign Currency ,
Forfeiture ,
Fraud ,
Non-Prosecution Agreements ,
Restitution ,
Securities Fraud ,
Spoofing ,
U.S. Treasury ,
UK ,
Wire Fraud
With the holiday season upon us, companies waiting for a nice surprise this Christmas are more likely to find a lump of coal in their stocking. In a series of recent announcements, Department of Justice (“DOJ”) officials have...more
When companies get into trouble, it’s common practice for the government to call on independent third parties to help clean up the mess.
Companies under investigation by the Department of Justice (“DOJ”) often agree to...more
A new sheriff is in town — and that means the potential for big changes ahead for white-collar criminal enforcement in terms of specific areas of focus and volume of investigations...more
6/25/2021
/ Attorney General ,
Biden Administration ,
Consumer Financial Protection Bureau (CFPB) ,
Coronavirus/COVID-19 ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Environmental Justice ,
Federal Trade Commission (FTC) ,
Foreign Corrupt Practices Act (FCPA) ,
No-Poaching ,
White Collar Crimes
One of the unique, and often overlooked, investigative bodies in Washington, D.C. is the United States Congress. With Representatives and Senators in constant fundraising and re-election cycles and the constant challenge of...more
While everyone expects the Department of Justice (“DOJ”), Securities and Exchange Commission (“SEC”) and other well-known enforcement agencies to increase enforcement under the Biden administration, few people are talking...more
As the Biden Administration gains its footing and key positions begin to be filled in the government, there promises to be a significant uptick in enforcement, especially in the areas of antitrust and white collar crime. In...more
Two weeks ago, the Department of Justice (“DOJ”) announced two significant enforcement actions and shut down NetWalker and Emotet, powerful tools that had been used by alleged criminal networks engaging in widespread...more
On December 16, 2020, the SEC passed a new rule which will require publicly traded companies operating in the oil and gas industries to disclose payments that they make to foreign governments. The SEC voted to adopt rules...more
During a roundtable at the Fifth International Debarment Colloquium last month, Joseph Mauro, a spokesperson for the Compliance Unit of the World Bank Group’s (“World Bank”) Integrity Vice Presidency (“INT”), announced recent...more
On October 22, 2020, the Securities and Exchange Commission (the “SEC” or “Commission”) announced a $114 million whistleblower award—by far the largest amount ever awarded and more than doubling the previous record of nearly...more
On October 8, 2020, the Attorney General’s Cyber-Digital Task Force (“the Task Force”) issued its Cryptocurrency Enforcement Framework (the “Report”), which offers background on virtual assets, enforcement milestones, and...more
10/22/2020
/ AML/CFT ,
CFTC ,
Cryptocurrency ,
Department of Justice (DOJ) ,
Digital Currency ,
FATF ,
Federal Reserve ,
IRS ,
Money Laundering ,
OCC ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Securities and Exchange Commission (SEC) ,
Virtual Currency
On September 10, 2020, the Commodity Futures Trading Commission (“CFTC”) Division of Enforcement released its long-awaited “Guidance on Evaluating Compliance Programs in Connection with Enforcement Matters,” which will be...more
On Sunday, September 6, 2020, the Washington Post reported that U.S. Postmaster General Louis DeJoy’s former North Carolina–based company allegedly used company funds to reimburse employees for donations to federal and state...more
On September 6, 2020, news broke that U.S. Postmaster General Louis DeJoy’s former company allegedly reimbursed its employees with corporate funds for donations that he asked them to make to federal and state political...more
In a significant move toward more transparency, the Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) released new guidance (the “Guidance”) on August 18, 2020, setting forth its enforcement approach and...more
8/24/2020
/ Bank Secrecy Act ,
Chief Compliance Officers ,
Civil Monetary Penalty ,
Corporate Counsel ,
Department of Justice (DOJ) ,
Enforcement Actions ,
FinCEN ,
New Guidance ,
Piling-On ,
Remediation ,
Self-Reporting ,
U.S. Treasury
On Friday, July 17, 2020, Special Inspector General for Pandemic Recovery (SIGPR) Brian D. Miller and U.S. Attorney for the Eastern District of Virginia (EDVA) G. Zachary Terwilliger announced a formal partnership to pursue...more
On June 25, 2020, Novartis AG, a Swiss multinational pharmaceutical company, and two subsidiaries reached a combined $345 million resolution with the U.S. Department of Justice (“DOJ”) and the U.S. Securities and Exchange...more
7/16/2020
/ Bribery ,
Cease and Desist Orders ,
Corporate Counsel ,
Department of Justice (DOJ) ,
DPA ,
Foreign Corrupt Practices Act (FCPA) ,
Health Care Providers ,
Novartis ,
Pharmaceutical Industry ,
Popular ,
Securities and Exchange Commission (SEC) ,
Vietnam
On July 3, 2020, the U.S. Department of Justice (“DOJ”) and the U.S. Securities and Exchange Commission (“SEC”) published the Second Edition of “FCPA: A Resource Guide to the U.S. Foreign Corrupt Practices Act” (the “Guide”)....more
In early June, federal agencies brought some of the first enforcement actions against COVID-19 securities fraudsters, involving over $100 million in fraudulent claims and profits, making good on their promise to investigate...more
In a novel and aggressive move likely aimed at garnering goodwill with federal regulators, Venezuelan state-owned entity CITGO Petroleum Company (“CITGO”) has sued its former agent for harm CITGO alleges was caused by the...more
6/4/2020
/ Asset Recovery ,
Bribery ,
Citgo ,
Crime Victims ,
Criminal Liability ,
Department of Justice (DOJ) ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Investment ,
Oil & Gas ,
Popular ,
Venezuela
In a little-noticed move yesterday, the U.S. Department of Justice (“DOJ” or “Department”) quietly amended its most important guidance document on corporate compliance. While the updates are far from a dramatic overhaul, they...more
Scrutiny into Paycheck Protection Program Loans Intensifies — Attracts SEC Attention-
Public companies applying for Paycheck Protection Program (“PPP”) loan funds have been under increasing political and media scrutiny....more
The coronavirus pandemic continues to upend the global economy and is increasing compliance risks for businesses in the process. We have previously reported how COVID-19 is increasing risks relating to insider trading and...more