On May 12, 2025, the U.S. Department of Justice ("the DOJ" or "the Department") unveiled its new playbook for prosecuting white-collar and corporate crime. DOJ announced enforcement priorities for the Criminal Division ("the...more
Paul Atkins has taken the reins of the US Securities and Exchange Commission (SEC). After being confirmed by the Senate on April 9, Atkins officially began his tenure as SEC Chairman on April 21. His arrival is expected to...more
4/22/2025
/ Artificial Intelligence ,
Cryptocurrency ,
Digital Assets ,
Enforcement Actions ,
Enforcement Priorities ,
Foreign Corrupt Practices Act (FCPA) ,
Private Funds ,
Regulatory Reform ,
Regulatory Requirements ,
Securities and Exchange Commission (SEC) ,
Securities Regulation ,
Technology Sector
On February 5, 2025, President Trump's nominee to lead the Justice Department (the "Department"), Pamela Bondi, was confirmed by the Senate to serve as the U.S. Attorney General. Bondi immediately took action to reshape the...more
On February 10, 2025, President Trump signed an executive order instructing the Attorney General of the United States to pause enforcement of the Foreign Corrupt Practices Act ("FCPA") and to issue updated guidelines for...more
2/13/2025
/ Anti-Corruption ,
Attorney General ,
Compliance ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Enforcement ,
Executive Orders ,
Foreign Corrupt Practices Act (FCPA) ,
Legislative Agendas ,
National Security ,
Regulatory Agenda ,
Trump Administration ,
White Collar Crimes
2024 marks the final year of Gary Gensler's term as Chair of the U.S. Securities and Exchange Commission ("SEC"). The Gensler SEC has been aggressive on both the enforcement and rulemaking fronts. In response, the financial...more
12/23/2024
/ Artificial Intelligence ,
Capital Markets ,
Cryptocurrency ,
Cybersecurity ,
Disclosure Requirements ,
Enforcement ,
Enforcement Priorities ,
Financial Markets ,
Fund Managers ,
Gary Gensler ,
Insider Trading ,
Investment Management ,
Machine Learning ,
Pay-To-Play ,
Presidential Nominations ,
Regulatory Agenda ,
Regulatory Requirements ,
Reporting Requirements ,
Rulemaking Process ,
SCOTUS ,
SEC v Jarkesy ,
Securities and Exchange Commission (SEC) ,
Technology Sector ,
Trump Administration ,
Whistleblower Protection Policies
On October 10, TD Bank pleaded guilty to violations of the Bank Secrecy Act and conspiracy to commit money laundering. The plea agreement outlines the facts that led to the charges and the consequences the Bank and its parent...more
Over the past year, the Department of Justice ("DOJ") has warned that it will seek stiffer sentences for offenses made significantly more dangerous by the misuse of artificial intelligence ("AI") and has asked the US...more
On August 28, 2024, FinCEN issued a long-awaited final rule meant to address illicit finance activities and national security threats in the asset management industry. The new rule imposes similar requirements on investment...more
9/17/2024
/ AML/CFT ,
Anti-Money Laundering ,
Bank Secrecy Act ,
Broker-Dealer ,
Exempt Reporting Advisers (ERAs) ,
Final Rules ,
Financial Crimes ,
FinCEN ,
Investment Adviser ,
National Security ,
Registered Investment Advisors
In early 2024, we published alerts on separate sets of remarks from Department of Justice ("DOJ") Deputy Attorney General Lisa Monaco warning that the DOJ would be seeking stiffer sentences for offenses made significantly...more
On June 27, 2024, the Supreme Court ruled in SEC v. Jarkesy that when the Securities and Exchange Commission (SEC) seeks civil penalties from defendants for securities fraud, the Seventh Amendment requires it to bring the...more
7/2/2024
/ Administrative Authority ,
Administrative Law Judge (ALJ) ,
Administrative Proceedings ,
Constitutional Challenges ,
Enforcement Actions ,
Jury Trial ,
SCOTUS ,
SEC v Jarkesy ,
Securities and Exchange Commission (SEC) ,
Securities Fraud ,
Securities Regulation ,
Separation of Powers ,
Seventh Amendment
On May 13, 2024, FinCEN and the SEC jointly proposed a new rule that would require SEC-registered investment advisers and exempt reporting advisers to maintain written customer identification programs (CIPs). The new rule...more
5/21/2024
/ AML/CFT ,
Anti-Money Laundering ,
Asset Management ,
Bank Secrecy Act ,
Broker-Dealer ,
BSA/AML ,
Comment Period ,
FinCEN ,
Investment Adviser ,
New Rules ,
Public Comment ,
Registered Investment Advisors ,
Regulatory Reform ,
Regulatory Requirements ,
Reporting Requirements ,
Risk Assessment ,
Risk Management ,
Securities and Exchange Commission (SEC)
Over the past few months, the Securities and Exchange Commission (the "SEC") has issued several warnings to companies to ensure accurate disclosure of the role and risks of artificial intelligence ("AI") in their businesses....more
In February 2024, we published an alert concerning the increase in regulatory attention to "AI washing," or making unfounded claims regarding artificial intelligence ("AI") capabilities. Notably, on February 14, 2024,...more
During the American Bar Association's 39th National Institute on White Collar Crime, Deputy Attorney General (DAG) Lisa Monaco announced the launch of the U.S. Department of Justice's (DOJ or the Department) pilot program to...more
3/14/2024
/ American Bar Association (ABA) ,
Corporate Misconduct ,
Corruption ,
Department of Justice (DOJ) ,
Federal Pilot Programs ,
Foreign Corrupt Practices Act (FCPA) ,
Incentives ,
Jurisdiction ,
Securities and Exchange Commission (SEC) ,
Whistleblower Awards ,
Whistleblowers
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 February 13, 2024, FinCEN proposed a long-awaited rule to combat illicit finance and national security threats in the asset management industry. The new rule would impose similar requirements on investment advisers that...more
2/22/2024
/ AML/CFT ,
Anti-Money Laundering ,
Asset Management ,
Bank Secrecy Act ,
BSA/AML ,
FinCEN ,
Investment Adviser ,
National Security ,
Proposed Regulation ,
Proposed Rules ,
Registered Investment Advisors ,
Securities and Exchange Commission (SEC) ,
U.S. Treasury
The SEC is Keeping a Watchful Eye on Companies' Claims about their AI Capabilities and Issued a Recent Warning: Don't "AI-Wash" -
In July 2023, the SEC proposed new rules that would require broker-dealers and investment...more
On October 4, 2023, United States Deputy Attorney General (DAG) Lisa Monaco announced a new Department of Justice (DOJ) Mergers & Acquisitions Safe Harbor policy that encourages companies to self-disclose criminal misconduct...more
12/4/2023
/ Acquisitions ,
Anti-Money Laundering ,
Antitrust Division ,
Compliance ,
Cooperation ,
Corporate Counsel ,
Corporate Crimes ,
Corporate Misconduct ,
Department of Justice (DOJ) ,
Disgorgement ,
Enforcement ,
EU ,
France ,
Germany ,
Mergers ,
Money Laundering ,
Poland ,
Policies and Procedures ,
Policy Statement ,
Popular ,
Remediation ,
Restitution ,
Safe Harbors ,
Spain ,
Voluntary Disclosure
On October 4, 2023, United States Deputy Attorney General (DAG) Lisa Monaco announced a new Department of Justice (DOJ) Mergers & Acquisitions Safe Harbor policy that encourages companies to self-disclose criminal misconduct...more
11/10/2023
/ Acquisitions ,
Antitrust Division ,
Corporate Crimes ,
Corporate Governance ,
Corporate Misconduct ,
Department of Justice (DOJ) ,
Enforcement ,
Mergers ,
Policies and Procedures ,
Policy Statement ,
Remediation ,
Safe Harbors