This week, the CFTC released an Enforcement Advisory setting forth concrete guidelines for self-reporting, cooperation and remediation that will reshape how market participants report and defend potential violations....more
Earlier this year, as described in a previous client alert, the Department of Justice (“DOJ”) Criminal Division announced a landmark pilot program to pay monetary awards to whistleblowers (the “Program”). At that time, Deputy...more
8/9/2024
/ Asset Recovery ,
Bribery ,
CFTC ,
Corporate Misconduct ,
Department of Justice (DOJ) ,
False Claims Act (FCA) ,
FEPA ,
Financial Crimes ,
FinCEN ,
Foreign Corrupt Practices Act (FCPA) ,
Healthcare Fraud ,
Incentives ,
Money Laundering ,
Popular ,
Securities and Exchange Commission (SEC) ,
Whistleblower Awards ,
Whistleblowers
On October 17, 2023, the Commodity Futures Trading Commission’s (“CFTC” or “Commission”) Division of Enforcement (“DOE”) released its latest enforcement advisory, providing guidance to CFTC staff on resolution of an...more
Happy New Year! While the holidays hopefully provided a chance to rest and recharge, things have not slowed down in the world of digital asset enforcement. We see a growing dedication of resources by government law...more
1/13/2023
/ Bank Secrecy Act ,
CFTC ,
Cryptocurrency ,
Decentralized Autonomous Organization (DAO) ,
Decentralized Finance (DeFi) ,
Department of Justice (DOJ) ,
FDIC ,
FinCEN ,
Fraud ,
Ponzi Scheme ,
Popular ,
Securities and Exchange Commission (SEC) ,
Securities Exchange Act ,
Suspicious Activity Reports (SARs) ,
Wire Fraud
The FTC recently concluded that many noncompete agreements between employers and employees violate federal antitrust law. These actions represent a rejection of the centuries-old principle that noncompete provisions are...more
Users of ephemeral messaging applications may intend that their messages be—as the word “ephemeral” suggests—short lived, but the real-world consequences and legal ramifications from improper use of such apps can be anything...more
10/7/2022
/ Books & Records ,
Broker-Dealer ,
CFTC ,
Compliance ,
Department of Justice (DOJ) ,
Electronic Communications ,
Enforcement ,
Federal Trade Commission (FTC) ,
Foreign Corrupt Practices Act (FCPA) ,
Instant Messaging Apps ,
Investment Adviser ,
Recordkeeping Requirements ,
Securities and Exchange Commission (SEC) ,
Snapchat ,
WhatsApp
We knew there would be plenty to write about each month, and so we start with a mention of the White House’s Framework for Responsible Development of Digital Assets, issued on September 16, 2022....more
10/4/2022
/ CFTC ,
CID ,
Commodity Exchange Act (CEA) ,
Consumer Financial Protection Bureau (CFPB) ,
Cryptocurrency ,
Decentralized Finance (DeFi) ,
Department of Justice (DOJ) ,
Digital Assets ,
Federal Trade Commission (FTC) ,
FinTech ,
OCC ,
Office of Foreign Assets Control (OFAC) ,
SAR ,
SDN List ,
U.S. Treasury ,
Unregistered Securities