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The Tornado Cash Trial’s Mixed Verdict: Implications for Developer Liability

On August 6, 2025, following a four-week trial, a jury in the Southern District of New York delivered a mixed verdict in the criminal case against Tornado Cash co-founder Roman Storm. The jury convicted Storm of conspiring to...more

President Trump Signs Debanking Executive Order

On August 7, 2025, President Donald Trump issued an Executive Order entitled “Guaranteeing Fair Banking for All Americans” (the “Order”). The Order announces the Administration’s plan to address the exclusion of certain...more

CFTC Issues Guidance for Referrals of Criminal Regulatory Offenses to DOJ

On July 9, 2025, the Commodity Futures Trading Commission (CFTC) issued an advisory describing its plan to address criminally liable regulatory offenses in accordance with Executive Order 14294, Fighting Overcriminalization...more

FinCEN's First Strike: New Section 311 Powers Target Mexican Financial Institutions Under FEND Off Fentanyl Act

In this episode, host Lauren Pryor and her colleagues discuss the recent actions by FinCEN, which designated three Mexican financial institutions as primary money laundering concerns under the expanded Section 311 authority,...more

FinCEN Designates Three Mexican Financial Institutions Under New Section 311 Authority: First Use of Expanded Powers Under FEND...

On June 25, 2025, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued three orders (the “Orders”) pursuant to the Fentanyl Sanctions Act and the FEND Off Fentanyl Act, designating three...more

FCPA Un-Paused: DOJ Announces New Guidelines for FCPA Enforcement

On June 9, 2025, in a memorandum entitled Guidelines for Investigations and Enforcement of the FCPA(the “Guidelines”), the Department of Justice (DOJ) signaled that Foreign Corrupt Practices Act (FCPA) investigations and...more

DOJ Announces White-Collar Enforcement Priorities and Revised Policies

On May 12, 2025, the Criminal Division of the US Department of Justice (DOJ) issued new guidance on white-collar enforcement priorities and revised its policies on corporate voluntary self-disclosure (VSD), the selection of...more

The Future of Anti-Corruption Enforcement: Potentially Increasing State and Non-US Prosecutions as an Alternative to the FCPA

On February 10, 2025, President Donald Trump signed an executive order instructing the United States Department of Justice (“DOJ”) to pause enforcement of the Foreign Corrupt Practices Act (“FCPA”) for a period of 180 days....more

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