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Congress Amends Exchange Act Of 1934 To Address Disgorgement Penalties In Defense Spending Bill

The New Year is still young, but major changes are already afoot in securities enforcement as Congress amended the Securities Exchange Act of 1934 (“Exchange Act”) on January 1, 2021. It was easy to miss these changes to the...more

A Long Time Coming: DOJ Issues First FCPA Advisory Opinion in Six Years

On August 14, 2020, the Department of Justice issued a Foreign Corrupt Practices Act (“FCPA”) Advisory Opinion—the first of its kind in nearly six years. The DOJ’s opinion advised a U.S. investment company that the...more

Top Three FARA Exemptions to Know

With the Department of Justice (“DOJ”) giving increased attention to Foreign Agent Registration Act (“FARA”) enforcement, companies that have international business operations or otherwise deal with foreign governments and...more

Emerging Trend: DOJ Turns to Rarely Used FARA Statute in Recent Surge in Prosecutions

Earlier this year, the Assistant Attorney General for the National Security Division publicly confirmed the Department of Justice’s (“DOJ”) intention to make Foreign Agents Registration Act (“FARA”) a criminal enforcement...more

Shift in DOJ Policy May Benefit Corporations and Individuals Under Investigation for Corporate Wrongdoing

In a shift in policy, Deputy Attorney General Rod Rosenstein announced on November 29, 2018, that the DOJ would relax certain policies, dating back to 2015...more

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