In February, the White House issued an Executive Order "pausing" Foreign Corrupt Practices Act (FCPA) enforcement for 180 days, to "further American economic and national security."1 On June 9, Deputy Attorney General Todd...more
6/24/2025
/ Attorney General ,
Bribery ,
Cartels ,
Corruption ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Enforcement Priorities ,
Executive Orders ,
Foreign Corrupt Practices Act (FCPA) ,
National Security ,
Regulatory Reform ,
Significant Transnational Criminal Organization ,
Voluntary Disclosure ,
White Collar Crimes
If a defendant uses material misrepresentations to induce a party to enter a contract, but does not economically harm the induced party, has the defendant committed fraud? The Supreme Court has decided: Yes. On May 22, 2025,...more
In March, the Department of Justice (DOJ) announced that a pilot program to incentivize individualized reporting was in development, which we reviewed here. True to its word, the DOJ's "Corporate Whistleblower Awards Pilot...more
8/12/2024
/ Corporate Misconduct ,
Corruption ,
Department of Justice (DOJ) ,
Enforcement Priorities ,
Federal Pilot Programs ,
Financial Crimes ,
Healthcare Fraud ,
Incentives ,
Pilot Programs ,
Public Corruption ,
Voluntary Disclosure ,
Whistleblower Awards ,
Whistleblowers ,
White Collar Crimes
On June 27, 2024, the U.S. Supreme Court affirmed a Fifth Circuit decision that called into question the future of certain in-house administrative enforcement actions, which we reviewed here. Specifically, in Securities and...more
7/9/2024
/ Administrative Authority ,
Administrative Law Judge (ALJ) ,
Administrative Proceedings ,
Civil Monetary Penalty ,
Enforcement Actions ,
Jury Trial ,
SCOTUS ,
SEC v Jarkesy ,
Securities and Exchange Commission (SEC) ,
Securities Fraud ,
Securities Regulation ,
Seventh Amendment
The Department of Justice's (DOJ) Deputy Attorney General Lisa O. Monaco announced a department-wide whistleblower rewards program on March 7, 2024, that will be designed to supplement existing whistleblower programs, to...more
3/22/2024
/ CFTC ,
Compliance ,
Corporate Misconduct ,
Department of Justice (DOJ) ,
Financial Services Industry ,
Pilot Programs ,
Securities and Exchange Commission (SEC) ,
Voluntary Disclosure ,
Whistleblower Awards ,
Whistleblowers ,
White Collar Crimes
On May 11, 2023, in Percoco v. United States, 598 U.S. ___ (2023), the U.S. Supreme Court once again reined in an expansive public corruption prosecution brought by the Department of Justice by overturning a wire fraud...more
On March 3, 2023, Assistant Attorney General Kenneth Polite delivered the keynote speech at the 38th Annual National Institute on White Collar Crime of the American Bar Association (ABA) in Miami, Florida. AAG Polite's speech...more
On September 15, 2022, Deputy Attorney General Lisa Monaco of the U.S. Department of Justice (DOJ) issued a Memorandum supplementing prior DOJ guidance on corporate criminal enforcement policies, titled Further Revisions to...more
On May 18, 2022, the Fifth Circuit issued its opinion in Jarkesy v. SEC, holding that: (1) the Securities and Exchange Commission's (SEC's) in-house adjudication of Petitioners' case violated their Seventh Amendment right to...more
On March 21, 2022, the U.S. Securities and Exchange Commission (SEC) released its much-anticipated proposed rule titled "The Enhancement and Standardization of Climate-Related Disclosures for Investors." The proposed enhanced...more
3/31/2022
/ Climate Change ,
Corporate Governance ,
Disclosure Requirements ,
Environmental Social & Governance (ESG) ,
Greenhouse Gas Emissions ,
Proposed Rules ,
Publicly-Traded Companies ,
Regulation S-K ,
Regulation S-X ,
Securities Act of 1933 ,
Securities and Exchange Commission (SEC) ,
Securities Exchange Act